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HMRC internal manual

Compliance Handbook

How to do a compliance check: establishing the facts: asking for information: UK / Swiss tax cooperation agreement: working the intervention

Once the response to the Exchange of Information (EOI) has been received the person will be aware of the exchange of information with the Swiss. You may well decide that the most constructive way forward is to discuss this directly with the person.

If the person refuses to cooperate, you will need to consider obtaining detailed statements of the bank account you have been made aware of. You should now have sufficient evidence to approach the person with a formal request under Paragraph 1 Schedule 36 for bank statements for the relevant period under their power or possession. If the person continues to deny the existence of the account without further justification, the EOI response will provide compelling evidence in support of your position at any subsequent tribunal.

If the request is successful you must keep a record of the additional yield.

When the case has been settled you should provide details by email to the same inbox as the original request HMRC, Swiss Agreement (SI) of

  • the name of the taxpayer
  • the OCU reference (this will be provided by the OCU)
  • the Unique Tax Reference (UTR)
  • the additional liability.