Exchange of Information: Key concepts: Normal course of administration
HMRC cannot ask another tax administration to do something that it is not normal practice to do in the UK. Similarly, they cannot ask us to do something that is not within their normal practice.
There are no hard and fast rules but generally we should not ask other tax authorities to go to great lengths to find information where only small amounts of tax are concerned unless there is an important principle at stake.
(This content has been withheld because of exemptions in the Freedom of Information Act 2000)
In the UK we do not normally obtain information directly from a company’s competitors to help find a comparable uncontrolled price for transfer pricing purposes. We would not therefore ask another tax authority to find this information in another jurisdiction.