https://www.taxtmi.com/manuals?id=2903 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. en-us Wed, 21 Jun 2023 15:01:00 +0530 Sat, 27 Jan 2024 13:09:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/manuals?id=2903 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. Manuals Income Tax Wed, 21 Jun 2023 15:01:00 +0530 https://www.taxtmi.com/manuals?id=2903