Cross-Border Rulings: Direct and Indirect Taxation

The authors analyse the different approaches to transparency of rulings regarding cross-border transactions in respect of both direct and indirect taxation. They consider that the enhanced transparency and model approach to VAT and cross-border rulings could also apply in respect of direct taxation and acknowledge that the political agreement reached on 6 October 2015 on the Directive for automatic exchange of information on cross-border rulings is a step in the right direction.