IEIM510100 - Exchange of tax rulings: What is a ruling?
IEIM510100: Exchange of tax rulings: What is a ruling?
»Ê¹ÚÌåÓýapp 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. »Ê¹ÚÌåÓýappre 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.