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HMRC internal manual

International Exchange of Information Manual

Legal framework for exchange: Types of international agreement: Overview

There are three kinds of legal gateway potentially available to the UK for an exchange with another jurisdiction:

  • A bilateral Double Taxation Agreement (IEIM210100);

  • A bilateral Tax Information Exchange Agreement (IEIM210200); and

  • Multilateral exchange agreements.

The UK is party to two multilateral exchange agreements:

  • The EU Directive on Administrative Cooperation in the Field of Taxation, for exchanges with EU Member States (IEIM210400); and

  • The OECD/CoE Multilateral Convention on Mutual Administrative Assistance in Tax Matters (IEIM210300), for exchanges with nearly 100 jurisdictions worldwide.

In some cases, the UK will have multiple forms of agreement with a given jurisdiction –particularly where they and we are both a party to a multilateral agreement.  (This content has been withheld because of exemptions in the Freedom of Information Act 2000)