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HMRC internal manual

International Exchange of Information Manual

Legal framework for exchange: What we can exchange

The specific terms will vary by agreement, but in general all agreements will provide for the exchange of information that is foreseeably relevant for the administration, assessment, and enforcement of tax.  The key concept in terms of what can be exchanged is that it is foreseeably relevant (IEIM101300).

Exchange of information does not have to be by written correspondence or exchange of documents.  A meeting or telephone call is just as valid if this is the best medium for the exchange.  ‘Information’ can include the knowledge or experience of the other jurisdiction.

In addition to the tax uses noted, the majority of agreements will allow for use in public court proceedings (IEIM101800) related to the taxes covered by the agreement.

The information will be exchanged for the purposes of tax, but the receiving tax authority may see value for other purposes (such as law enforcement); some agreements will allow for such onward sharing of the information, within strict parameters (IEIM200300).

For examples of what is commonly exchanged see IEIM112000

IEIM130000 covers other forms of assistance that are possible under exchange agreements.