The Guernsey government has published a notice on the compulsory spontaneous exchange of information on tax ruling as set out in BEPS Action 5, which Guernsey will comply with. According to the notice, past rulings need to be exchanged with relevant tax authorities by 31 December 2017. For this purpose, past rulings mean:
- Rulings made between 1 January 2015 and 1 April 2017; and
- Rulings made between 1 January 2012 and 1 January 2015, if still in force at 1 January 2015.
There will be no …