The Council Directive (EU) 2015/2376 amends Directive 2011/16/EU to enhance the mandatory automatic exchange of information related to advance cross-border rulings and advance pricing arrangements among Member States. It identifies the need for greater transparency in the context of increased concerns about cross-border tax avoidance, aggressive tax planning, and harmful tax competition. The amendments require that such information be communicated promptly and include specific data elements for clarity, while allowing for certain exclusions based on defined criteria.

Member States are mandated to adopt the necessary measures by 31 December 2016, with implementation commencing on 1 January 2017. This includes establishing a central directory for storing and exchanging relevant information to facilitate compliance and monitoring. The provisions recognise the importance of confidentiality while ensuring that information exchanged does not compromise commercial secrets or public policy.