IEIM510400 | Exchange of tax rulings: With which jurisdictions to exchange

IEIM510400: Exchange of tax rulings: With which jurisdictions to exchange

The OECD requirement means that rulings and APAs will only be shared with those jurisdictions that have committed to implement the base erosion and profit shifting framework set out in Chapter 5 of Action 5.

HMRC is committed to honouring the spirit, as well as the letter, of the UK’s international treaty obligations with respect to exchange of information and will spontaneously exchange rulings that fall outside the scope of Action 5 where the information is foreseeably relevant to the treaty partner (IEIM530000+).