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HMRC internal manual

International Exchange of Information Manual

What and how to exchange: What to exchange for Action 5

IEIM570100: What and how to exchange: What to exchange for Action 5


The following information is required for every ruling:

  • The identification of the UK customer - name, address, UTR, name of group to which it belongs
  • Date of issue of ruling and years covered
  • Whether the ruling is new, an amendment, or renewal of an existing one
  • Type of ruling issued (for example unilateral APA, see IEIM541010)
  • Short summary of the ruling: there is further guidance and what to include in the notes attached to the template (IEIM570910)
  • Details of the entities in the recipient jurisdiction
  • For this you will need to have determined the ultimate and immediate parents, together with the entities of the related parties to the transaction (IEIM540400)


The following information is optional.  It should be provided if it would be helpful to the other tax administration and it is readily available:

  • Main business activity of the UK company, or of the permanent establishment
  • Transaction amount, if any
  • The annual turnover of the UK entity
  • Profit of the UK entity for the periods concerned

The information should be provided on the template at IEIM570900.