DAC3/BEPS Action 5
When and how information is exchanged
Deadline for exchange of rulings - Council Directive (EU) 2015/2376 (DAC3)
The exchange deadline is three months after the six-month period in which the ruling was issued. The two six-month periods are 1 January to 30 June and 1 July to 31 December. The exchange date for the period 1 January to 30 June is 30 September of the same year. The exchange date for the period 1 July to 31 December is 31 March of the following year.
Deadline for rulings – Base Erosion and Profit Shifting (BEPS) Action 5
Under BEPS Action 5, exchanges should happen:
- as soon as possible
- and
- no later than three months after the competent authority in the sending jurisdiction becomes aware that the ruling issued.