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Exchange of rulings

A key theme of the OECD's plan for combatting base erosion and profit shifting has been improved transparency. In 2015 G20 finance ministers endorsed a new international standard which requires Inland Revenue to exchange certain types of rulings with its tax treaty partners.

The standard applies to these types of rulings:

  • rulings related to preferential regimes
  • cross-border unilateral advance pricing agreements and any other cross-border unilateral tax ruling covering transfer pricing or the application of transfer pricing principles
  • cross-border rulings giving a unilateral downward adjustment to the taxpayer's taxable profits in the country giving the ruling
  • permanent establishment rulings, and
  • related party conduit rulings.

The obligation to exchange information on these rulings applies not only to future rulings, but also to past rulings that relate to earlier years. It was agreed that information on rulings that were issued on or after 1 January 2010 and were still in effect as from 1 January 2014 must be exchanged.

Inland Revenue began implementing this new standard during 2016.