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HMRC internal manual

International Exchange of Information Manual

Legal framework for exchange: Types of international agreement: Tax Information Exchange Agreements

A Tax Information Exchange Agreement (TIEA) is a bilateral agreement under which territories agree to cooperate on tax matters through exchange of information. They broadly follow the OECD model Agreement on Exchange of Information on Tax Matters.

See the TIEAs in force in the UK on

TIEAs are expressly drafted to cover exchange of information (though some also allow for assistance in collection).  They are commonly used where it is not appropriate to seek a full Double Tax Treaty because, for example, one or both of the jurisdictions does not have taxes on income.  Because they are much more limited in scope than treaties they are also, in theory, much simpler to negotiate and implement into law for the jurisdictions agreeing them. 

Because they are dedicated exchange of information agreements, the different forms of exchange are normally each covered in a different Article.  The taxes covered will normally be clear from Article 2.  (This content has been withheld because of exemptions in the Freedom of Information Act 2000)

TIEAs are brought into UK law through Regulations dedicated to each TIEA or amendment to a TIEA; these are made under the powers in in FA06/s173.