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HMRC internal manual

International Exchange of Information Manual

What and how to exchange: Overview

IEIM570010: What and how to exchange: Overview

Both the Action 5 and the DAC set out the information that is to be exchanged.  The template at IEIM570900 meets both the requirements for Action 5 and the DAC. Guidance on the completion of the form is embedded within it and is reproduced at IEIM570910.

The completed template should be sent to the JITSIC email address together with a copy of the request from the customer and the ruling or APA, issued. This will assist with JITSIC with any follow-up requests for further information by other tax administrations.

For bilateral APAs with third countries (i.e. non EU), the template should be completed based on the request for the APA.  JITSIC do not require a copy of the bilateral APA with the third country, but instead need to have the expression of interest information and the request for the APA.   The information should be sent only when the APA is agreed.  There is further guidance on this aspect at IEIM550500.