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HMRC internal manual

Compliance Handbook

From
HM Revenue & Customs
Updated
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How to do a compliance check: establishing the facts: asking for information: UK / Swiss tax cooperation agreement: contacting the person

Where appropriate, OCU will contact the person before submitting the request to the Centre for Exchange of Information. You must not contact the person or give any indication in advance that HMRC will be making a request under the agreement.

However, if you have reasonable grounds for believing that contact would seriously prejudice the assessment or collection of tax, you must include an explanation in your accompanying email as to why. OCU will take this information into account when making the decision to contact the person. A member of OCU may well contact you to discuss the matter further.

When making the request, bear in mind that the agreement provides that the Swiss Federal Tax Authority must in all cases, where accounts are found, contact the UK person before exchanging any information with HMRC. You will need to consider the potential implications for your enquiry of the person being informed at that point of the pending exchange.