Transparency in tax rulings: compulsory spontaneous exchange of taxpayer specific rulings to counter cross border tax base erosion.

Action 5 establishes a transparency framework requiring compulsory spontaneous exchange of taxpayer specific rulings where lack of exchange could give rise to BEPS concerns, covering six categories of rulings (including preferential regime rulings, unilateral transfer pricing rulings, downward profit adjustments, permanent establishment rulings, conduit rulings, and other BEPS relevant rulings). The framework is supported by 2019 guidance standardising exchange modalities and IT formats (NTJ XML Schema), with annual monitoring of compliance by participating no or only nominal tax jurisdictions to enable recipient administrations to apply anti BEPS measures.

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