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HMRC internal manual

International Exchange of Information Manual

What and how to exchange: What to exchange for the DAC

IEIM570200: What and how to exchange: What to exchange for the DAC

The basic requirements under the DAC are very similar to those required for Action 5 (IEIM570100), though there are differences in what is and is not mandatory.  There are additional requirements, the complete list is given below.

The ultimate and immediate parent should be identified to assist in the identification of the Member States concerned, but there is no need to exchange with these jurisdictions specifically (IEIM550300).

For bilateral APAs, with non-EU countries, the information should be provided based on the application for the bilateral APA, not the APA itself (IEIM550500).  The information required is:

  • 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, permanent establishment clearance)
  • Short summary of the ruling, there is further guidance and what to include in the notes attached to the template
  • Names of the other MSs, if any, likely to be concerned by the ruling, there is no definition of the word concerned, and so it should take its everyday meaning
  • The identification of other persons likely to be affected by the ruling.  This will be:
  • The ultimate and immediate parent of the UK entity.  If either the ultimate or immediate parent is not resident in the UK please also provide their addresses together with the overseas tax reference numbers, if known.


But it will also include one of the following:

  • The related party to the cross-border transaction
  • The persons involved in a series of transactions for which a ruling has been given
  • The person who has a permanent establishment in the UK


Additionally, for APAs only:

  • A description of the set of criteria used for the determination of the transfer price
  • The identification of the method used for determination of the transfer price