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HMRC internal manual

Inheritance Tax Manual

Foreign property: Double Taxation Conventions: exchange of information: why exchange information?

One of the purposes of Double Taxation Conventions is to provide rules for exchanging relevant information between the two contracting countries.

To exchange information we must send a bulletin (form 730 - IHTM27164) detailing the assets on which the other country might have a claim. What information is provided in the bulletin depends largely on the domicile (IHTM13001) of the deceased. Remember that this applies not only when someone becomes beneficially entitled to property following a death but also when they get a capital distribution from a settlement (except in the case of exchanges with France, Italy and Switzerland).

Convention partners will send us bulletins to notify us that we may have a claim to tax, for example, F2092 from the USA, or CA52 from Ireland.

Where specific information is required from a foreign taxation authority that has a Double Taxation Convention with the UK, Technical (Nottingham) may be able to obtain it by writing directly to the foreign taxation authority. This also applies where foreign taxation authorities have a TIEA (Tax Information Exchange Agreement) with the UK or where the country concerned is a signatory to the OECD Convention on Mutual Administrative Assistance in Tax Matters.

A list of the territories with which the UK has a TIEA can be found on the HMRC website. External customers can find this guidance at . Technical can advise with regard to the OECD Convention.