IEIM570100 - What and how to exchange: What to exchange for Action 5

IEIM570100: What and how to exchange: What to exchange for Action 5

»Ê¹ÚÌåÓýapp following information is required for every ruling:

  • »Ê¹ÚÌåÓýapp identification of the UK customer - name, address, UTR, name of group to which it belongs
  • Date of issue of ruling and years covered
  • Whether the ruling is new, an amendment, or renewal of an existing one
  • Type of ruling issued (for example unilateral APA, see IEIM541010)
  • Short summary of the ruling: there is further guidance and what to include in the notes attached to the template (IEIM570910)
  • Details of the entities in the recipient jurisdiction
  • For this you will need to have determined the ultimate and immediate parents, together with the entities of the related parties to the transaction (IEIM540400)

»Ê¹ÚÌåÓýapp following information is optional. It should be provided if it would be helpful to the other tax administration and it is readily available:

  • Main business activity of the UK company, or of the permanent establishment
  • Transaction amount, if any
  • »Ê¹ÚÌåÓýapp annual turnover of the UK entity
  • Profit of the UK entity for the periods concerned

»Ê¹ÚÌåÓýapp information should be provided on the template at IEIM570900.