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HMRC internal manual

International Exchange of Information Manual

Exchange of Information: Joint audits

There will be circumstances with multinational enterprises, and some high- net worth individuals with complex international affairs, where it will be beneficial for multiple tax authorities to work together in a joint audit.  These are sometimes called Multilateral Controls, or MLCs.

This sort of closer working is increasingly common, particularly where there are transactions that cross borders, or the business has a company or team that performs the same functions in multiple territories (such as a group services company that performs services for trading entities across Europe).

Two jurisdictions can work together on a joint audit providing the bilateral agreement between them allows for this.  Joint audits with more than two participating jurisdictions will need to use a multilateral agreement that allows for such collaboration, such as the EU Directive on Administrative Cooperation or the OECD Multilateral Convention on Assistance in Tax.

Within the EU, funding may be available to work with tax authorities of other Member States under the Fiscalis programme. 

Joint audits must be facilitated by a Competent Authority.  (This content has been withheld because of exemptions in the Freedom of Information Act 2000)