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HMRC internal manual

International Exchange of Information Manual

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What and how to exchange: When to provide details of the ruling

IEIM570400: What and how to exchange: When to provide details of the ruling

It is best practice for staff in HMRC providing rulings to forward a completed template as at IEIM570900, plus any relevant documents, to JITSIC immediately after they provide the clearance or APA to the customer.  JITSIC can then handle the decisions on timing and make the exchange.

The strict deadlines are that JITSIC will need to exchange the rulings:

  • Action 5, JITSIC must exchange it no later than three months after the date on which it becomes available to JITSIC
  • DAC, within three months following the end of the half-year in which the ruling was issued, renewed or amended

 

It is best practice to send the completed template to JITSIC at the same time as providing your decision to the customer.

Where a ruling needs to be exchanged under both Action 5 and the DAC, the OECD timescale should be used, as this is quicker.

If you miss the timescale for exchange, you should still supply the ruling to JITSIC for exchange.

IEIM510500 has details of the start dates for the two obligations, and IEIM510550 has guidance on exchange of rulings made between 2010 and 2016.