IEIM520300 | What is a ruling: Types of ruling to be exchanged

IEIM520300: What is a ruling: Types of rulings to be exchanged

Action 5 lists specific types of rulings that give rise to base erosion and profit shifting concerns (IEIM540100).

Action 5 limits the rulings to be exchanged to five situations, all of which have the potential to give rise to base erosion and profit shifting concerns (IEIM541010).

If a ruling falls outside the Action 5 definition, but is foreseeably relevant to a treaty partner, you should look to spontaneously exchange it (IEIM530000).