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HMRC internal manual

International Exchange of Information Manual

Exchange of Information: Key concepts: Legal gateways

In order for HMRC to disclose information to another tax authority, we must have a legal gateway.  These gateways are based on exchange agreements signed between the UK and others, and brought into law through Regulations (IEIM200010).

The UK has an extensive network of bilateral Double Taxation Agreements (IEIM210100) and Tax Information Exchange Agreements (IEIM210200), which provide for exchange of information.

The UK is also a party to two multilateral agreements, whereby many jurisdictions agree through the same instrument to exchange with all other parties.  These are:

  • The OECD/Council of Europe Multilateral Convention on Mutual Administrative Assistance in Tax Matters.  This agreement has been ratified by nearly 100 jurisdictions, and the number is increasing (IEIM210300); and

  • The Directive on Administrative Cooperation in Taxation provides a legal gateway for exchanging with other Member States of the European Union (IEIM210400). 

All of these exchange agreements have certain things in common, and in particular the concepts of foreseeable relevance (IEIM101300), and exchange being done by a Competent Authority (IEIM101400).

There is more guidance on the legal framework at IEIM200000+.