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HMRC internal manual

International Manual

Non-residents trading in the UK: Exchangeability of Rulings

The UK has certain international obligations to exchange information about rulings issued by HMRC. These obligations arise out of bilateral treaties, the EU Directive on Administrative Cooperation in the field of Taxation (the DAC), and Action 5 of the OECD’s Base Erosion and Profit Shifting (BEPS) project.  Statutory and non-statutory clearances on the IME constitute agreements made between a tax authority and a customer, upon which the customer can rely. This makes them “rulings” for international taxation purposes, meaning they are very likely to be exchangeable with another jurisdiction:

  1. automatically, under BEPS Action 5;
  2. automatically, under the DAC; or
  3. spontaneously, where it would be foreseeably relevant to advise another jurisdiction.

For more information, including whether, when, and how to exchange such rulings: please consult IEIM500000+ onwards.  There may be information that you will need to collect from the customer, so it is important that you review the guidance on sharing rulings before you reply.