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HMRC internal manual

International Exchange of Information Manual

From
HM Revenue & Customs
Updated
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What and how to exchange: What to exchange for Action 5: Obtaining the information

IEIM570150: What and how to exchange: What to exchange for Action 5: Obtaining the information

You should seek the information before providing the ruling.

If the customer declines to provide the information it is suggested that you discuss the following with the customer in an effort to obtain it:

  • The importance of obtaining a holistic understanding of the customer’s arrangements and interaction with the parties to the arrangements.  In certain circumstances such information is vital and failure to provide the information may be grounds to decline the request for a ruling or APA
  • The information will be exchanged in accordance with the secrecy and disclosure provisions under our tax treaties
  • HMRC’s commitment to the implementation of the OECD transparency framework