doc 106
Ref. Ares(2016)293263 - 20/01/2016
ROOM DOCUMENT # 4
Code of Conduct Group (Business Taxation)
7 April 2015
ORIGIN: Commission Services
2011 Work Programme – Administrative Practices
1. In 2011 the Group agreed to monitor developments in administrative practices of Member
States, including tax ruling regimes.1 The review in spring 2012 showed that, despite the
agreed guidance, in practice no information on cross-border rulings was exchanged
spontaneously.
2. With a view to stimulating spontaneous exchange of information in relation to specific cross
border rulings the Group asked the Committee on Administrative Cooperation for Taxation
(“CACT”) to develop a "Model Instruction" that could be used as a reference by Member
States. This was then extended to include exchanges in the area of transfer pricing. The Model
Instruction was agreed in June 2014.2
3. The Commission Services would like to ask delegates the following questions;
• What progress has been made in implementing the Model Instruction in your Member
State?
• Has your Member State begun to automatically exchange rulings covered by the Model
Instruction?
_______________________
1 Document 17081/11 FISC 144.
2 Document 10608/14 FISC 95;
Model instruction for cross-border rulings and unilateral APAs (CACT 036);
Statistics:
guidelines and tables (CACT 037).
1