On 8 December 2015, the Council of the European Union adopted a directive for the mandatory automatic exchange of information between EU Member States on advance cross-border tax rulings and advance pricing agreements (APA). The automatic exchange was proposed by the European Commission in March 2015 and is also related to recommendations on tax rulings under Action 5 (Countering Harmful Tax Practices) of the OECD BEPS Project.
The automatic exchange will apply from 1 January 2017, including for information on rulings and APAs issued prior to that date as follows:
EU Member States will have the option to exclude information on rulings or APAs issued, amended or renewed before 1 April 2016 if the annual net revenue of the relevant group concerned is less than EUR 40 million. However, this will not apply for rulings or APAs concerning companies conducting mainly financial or investment activities.
EU Member States will need to adopt and publish the laws, regulations and administrative provisions necessary to comply with the information exchange rules by 31 December 2016.
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