A new Revenue Tax & Duty Manual sets out their arrangements for the communication to other Member States of information in respect of Revenue opinions/confirmations which are foreseeably relevant to tax administration and collection in those other Member States.

In brief, Council Directive 2011/16/EU on administrative cooperation in the field of taxation, provides for the exchange of information between the tax authorities of EU Member States. Specific requirements are imposed on the tax authorities and one of these requirements is to spontaneously exchange information, i.e. exchange information without having been requested to do so, that may be relevant to the administration and enforcement of the domestic taxation laws of that Member State.

The Revenue Tax & Duty Manual sets out examples of Revenue rulings to be spontaneously exchanged and the arrangements Revenue have put in place to meet the specific requirements under the Directive.