IEIM510100 - Exchange of tax rulings: What is a ruling?

IEIM510100: Exchange of tax rulings: What is a ruling?

The definition of rulings for the purposes of exchange of information, agreed at the OECD under Action 5 (IEIM540100) whereby a specific customer (or group of customers) being entitled to rely on the advice, information or undertaking provided by a tax authority concerning their tax situation.

Action 5 requires the exchange of APAs, including advance thin capitalisation agreements. There is further guidance on the definition of APA for this purpose at IEIM520200 (there is guidance on transfer pricing at INTM410000).

For guidance on general points, see IEIM520010.