Skip to content
Solved

IEIM541250 | Action 5 rulings: Types of rulings to exchange: Other rulings related to transfer pricing

From HM Revenue & Customs · International Exchange of Information Manual

IEIM541250: Action 5 rulings: Types of rulings to exchange: Other rulings related to transfer pricing

The requirement to exchange unilateral rulings relating to transfer pricing also extends to transfer pricing issues that fall short of a unilateral Advanced Pricing Agreement (APA) or Advance Thin Capitalisation Agreement (ATCA), such as:

  • A ruling that is limited to addressing questions of a legal nature based on the facts presented

  • A ruling that is binding only for a particular transaction (unlike an APA which usually covers several transactions, or all transactions for a given period of time)

  • An agreement on future transfer pricing methodology, future pricing of profit apportionment structure

As for actual APAs and ATCAs, such rulings will only need to be exchanged automatically under Action 5 where they are made unilaterally (IEIM541200).