On 8 December 2015, the Council of the European Union adopted a directive for the mandatory automatic exchange of information between EU Member States on advance cross-border tax rulings and advance pricing agreements (APA). The automatic exchange was proposed by the European Commission in March 2015 and is also related to recommendations on tax rulings under Action 5 (Countering Harmful Tax Practices) of the OECD BEPS Project. The automatic exchange will apply from 1 January 2017, including for information on rulings and APAs issued prior to that date as follows: Rulings and APAs issued, amended or renewed between 1 January...