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HMRC internal manual

International Exchange of Information Manual

Updates: International Exchange of Information Manual

2016

published amendments

Background: FATCA
Page republished
Background: AEOI Regimes
Page republished
Background: Status of Guidance
Page republished
Automatic Exchange of Information: background: contents
Page republished
Automatic exchange of financial accounts information
Page republished

published amendments

Investment Entity: Reporting on a Collective Investment Scheme
Image removed as attachment
Due Diligence: New Entity Accounts: Passive NFE, Controlling Persons
Image removed as attachment
Background: How it works
Image removed as attachment
Reportable Information: Non-Participating Financial Institutions: Dividends Paid by a Financial Institution
Image removed as an attachment

published amendments

Timetable: CDOT to CRS Transition
Sectioned Removed.
Timetable: FATCA reporting
Changed table properties.
Pre-Existing Individual Accounts: Lower Value Accounts: Standing Instructions
Including "Individual".
Due Diligence: Pre-Existing Individual Accounts: Lower Value Accounts: Telephone Number in Reportable Jurisdiction
Including "Individual".
Due Diligence: Pre-Existing Individual Accounts: Lower Value Accounts: Address Based on Documentary Evidence
Including "Individual".
Including "Individual".
Due Diligence: Pre-Existing Individual Accounts: Lower Value Accounts: Dormant Accounts
Including "Individual".
Including "Individual".
Due Diligence: Pre-Existing Individual Accounts: Lower Value Accounts: Current Residence Address
Including "Individual".
Including "Individual".
Due Diligence: Pre-Existing Individual Accounts: Lower Value Accounts: Residence Address Definition
Including "Individual".
Including "Individual".
Due Diligence: Pre-Existing Individual Accounts: Lower Value Accounts: Residence Address Test
Including "individual".
Including "Individual".
Due Diligence: Pre-Existing Individual Accounts: Lower Value Accounts: Introduction
Including "Individual".
Including "Individual".
Due Diligence: Pre-Existing Individual Accounts: Lower Value Accounts: Electronic Records Search
Including "Individual".
Including "Individual".
Due Diligence: Pre-Existing Individual Accounts: Lower Value Accounts: Electronic Records Search: Unambiguous US Place of Birth
Including "Individual".
Including "Individual".
Due Diligence: Pre-Existing Individual Accounts: Lower Value Accounts: Electronic Records Search: Mailing or Residence Address
Including "Individual".
Due Diligence: Pre-Existing Individual Accounts: Lower Value Accounts: Electronic Records Search: Resident of a Reportable Jurisdiction
Including "Individual".
Due Diligence: Pre-Existing Individual Accounts: Lower Value Accounts: Contents
Including the word "Individual" in the headings.
Including the word "Individual" to the headings.
Investment Entity: Reporting on a Collective Investment Scheme
Embedded image changed to link to allow page to publish on GOV.UK
Background: How it works
Embedded image changed to link to enable page to publish to GOV.UK

published amendments

Due Diligence: New Entity Accounts: Passive NFE, Controlling Persons
Link to diagram corrected
Reportable Information: Non-Participating Financial Institutions: Dividends Paid by a Financial Institution
Hyperlink to IEIM401700 corrected
Link to diagram corrected
Investment Entity: Reporting on a Collective Investment Scheme
Link to image corrected
Background: How it works
Link to image corrected
Timetable: CDOT to CRS Transition
Formatting amendment to remove table

published amendments

Timetable: Inter-Governmental Agreement dates
Obsolete link removed
Financial Institutions: Non-Reporting Financial Institutions: CDOT Only: CDOT Credit Unions
Title updated
Financial Institutions: Investment Entity: Contents
Title updated

published amendments

Investment Entity: Trusts Managed by a Financial Institution
Hyperlink to flowchart corrected

published amendments

Investment Entity: Trusts Managed by a Financial Institution
Link updated

published amendments

Timetable: FATCA reporting
Formatting change to remove table
Timetable: CDOT reporting
Formatting amendment to remove table
Timetable: CRS/DAC Reporting
Formatting amendment to remove table

published amendments

Timetable: CDOT to CRS Transition Detailed Guidance
Amendment to formatting.
Timetable: CDOT to CRS Transition
Additional line put to in to make reading easier.
Timetable: CDOT reporting
Amendment to formatting.
Timetable: FATCA reporting
Amendment to formatting.
Amendment to formatting.
Timetable: CRS/DAC Reporting
Amendment to formatting.
Amendment to formatting.
Amendments to formatting.
Amendment to formatting.
Amendment to formatting.
Amendment to formatting.

published amendments

Investment Entity: Trusts Managed by a Financial Institution
Flowchart link amended.
Timetable: FATCA reporting
Formatting amendment.

published amendments

Financial Institutions: Non-Participating Financial Institutions
Inserted a link to IEIM402360.
Timetable: Inter-Governmental Agreement dates
-
Updated to add extension to due diligence completion date to 31 December 2016 for pre-existing FATCA and CDOT accounts with a due diligence deadline of 30 June 2016.

published amendments

Due Diligence: Entity Accounts: Investment Entity with Regularly Traded Securities
Hyperlink amended.
Hyperlink added.
Miscellaneous: Contents
IEIM404050 added.

published amendments

Non-Financial Entity: Regularly Traded Definition
Typo in title amended.

published amendments

Investment Entity: Charities
Charities examples removed.
Examples page added.

published amendments

Due Diligence: Special Due Diligence Rules: Alternative Procedure for CIVC and Annuities
Corrected 3 incorrect spellings of alternative

published amendments

Investment Entity: Charities
Charities examples page added.

published amendments

Reportable Information: Reportable Account Holders
Paragraph amend and sentence added under CDOT section. "all" included in under CRS and DAC heading for regularly traded stock section.

published amendments

Due Diligence: Pre-Existing Entity Accounts: Reportable Accounts: Self-Certification: Financial Institutions
Page content amended.

published amendments

Investment Entity: Examples
-
Correct link to IEIM400770
Amended to include additional example on investments in real property.

published amendments

Reportable Information: Reportable Jurisdictions
Updated list of reportable jurisdictions to confirm the 2017 CRS reportable jurisdictions.

published amendments

Investment Entity: Charities
Added link to new specific charities guidance pages at IEIM404700+

published amendments

Charities: Contents
Add new link
Publishing
Automatic exchange of financial accounts information
Added charities contents page to main contents page
Investment Entity: Charities
Link to IEIM404700 for detailed charities guidance included.

published amendments

Action 5 rulings: Types of rulings to exchange: Other rulings related to transfer pricing
Changed title formatting to correct an error
Acton 5 rulings: Contents
Publish
Customers for whom rulings should be exchanged: Contents
Publish
What is a ruling: Contents
Publish
Publish
Publish
Action 5 rulings: Types of ruling to exchange: Contents
Publish
Guidance on exchange of tax rulings
Publish

published amendments

Exchange of tax rulings: Refusal to provide a ruling
Formatting
Exchange of tax rulings: When automatic exchange starts
Formatting
Exchange of tax rulings: With which jurisdictions to exchange
formatting
Exchange of tax rulings: Information not to be exchanged
Formatting
Add in content from IEIM510800 - page removed

published amendments

Due Diligence: Pre-Existing Individual Accounts: Lower Value Accounts: Hold Mail or In-Care-Of Address Only
Update to add wording on undocumented account equivalent to IEIM403100 for higher value accounts

published amendments

Reportable Information: Reportable Jurisdictions
Removal of Andorra as they are a 2018 adopter of the CRS.

published amendments

Notification requirement: Specified Relevant Persons: Summary
Republished to correct links on GOV.UK
Formatting amendments
Republish to correct links on GOV.UK
Formatting amendment
Notification requirement: Flowcharts: Contents
Formatting amendments
Notification requirement: Advice or services provided to staff
Formatting amendment
Notification requirement: Meaning of offshore advice or services: Offshore advice or services
Formatting amendment
Notification requirement: meaning of Relevant Person and Specified Relevant Person: flowcharts
Hyperlink to image corrected
Notification requirement: meaning of Relevant Person and Specified Relevant Person: flowcharts
Link to image corrected
Notification requirement: Scope and requirements:  Specified Financial Institution
Subsequent review to address issues identified with links.
Due Diligence: Pre-Existing Individual Accounts: Lower Value Accounts: Hold Mail or In-Care-Of Address Only
Wording corrected following previous update

published amendments

Notification requirement: meaning of Relevant Person and Specified Relevant Person: flowcharts
typo corrected
Added that link will be added in October 2016.
Hyperlink to image corrected
Notification requirement: meaning of Relevant Person and Specified Relevant Person: flowcharts
typo corrected
Added that link will not work until October 2016.
Hyperlink to image corrected
Notification requirement: Penalties for failure to send notification: contents
Republished to test section pages on GOV.UK
Notification requirement: Specified Relevant Persons: Group services companies
Republished to push link through to GOV.UK
Republished to push through link to GOV.UK
Notification requirement: Meaning of offshore advice or services: Services solely in preparation of a tax return
Republished to push through link to GOV.UK
Notification requirement: Specified Relevant Persons
Republished to push through hyperlinks to GOV.UK
Notification requirement: Scope and requirements: What should I send?
Republished to push through hyperlinks to GOV.UK
Notification requirement: Content and method of notification: contents
Republished to correct page address
Notification requirement: Meaning of offshore advice or services: contents
Republished to correct page address

published amendments

Reportable Information: Reportable Jurisdictions
Slight amendment to sentence below "CRS".
Amendment to text under CRS heading for clarification for which year reporting relates to.

published amendments

Notification requirement: Controlled persons overseas: Obligation on overseas persons
Removed the word "minor" before "a body corporate".
Change to definition of overseas person and correction of regulation reference.
Notification requirement: Specified Relevant Persons: Overseas Specified Relevant Persons who are bodies corporate or partnerships
Correction to definition of overseas person.

published amendments

Notification requirement: meaning of Relevant Person and Specified Relevant Person: flowcharts
Link to image now working
Notification requirement: meaning of Relevant Person and Specified Relevant Person: flowcharts
Link to image now working

published amendments

Notification requirement: Penalties for failure to send notification: When will a penalty apply?
Updated date of penalty window.
Notification requirement: Scope and requirements: What should I send?
Added link to PDF.
Notification requirement: Content and method of notification: HMRC notification document
Welsh notification caveat and link to English pdf added.

published amendments

Due Diligence: Pre-Existing Individual Accounts: Lower Value Accounts: Hold Mail or In-Care-Of Address Only
Correcting typo
Non-Financial Entity: Regularly Traded Definition
Spelling mistake in title corrected.

published amendments

Notification Requirement: Controlled parties overseas: Who the overseas person will need to notify
Added paragraphs on reasonable belief.
Notification requirement: Controlled persons overseas: Obligation on overseas persons
Added final paragraph.
Notification requirement: Specified Relevant Persons: Overseas Specified Relevant Persons who are bodies corporate or partnerships
Change of title to reflect previous change in text content.

published amendments

Notification Requirement: Controlled parties overseas: Control
Added line on control of a partnership.
Notification requirement: Controlled persons overseas: Obligation on overseas persons
Edit to wording in second paragraph.
Notification requirement: Specified Financial Institutions: Which clients to notify
Punctuation
Added in paragraph on Reg12b(4) and example.

published amendments

Notification requirement: Specified Financial Institutions: Which clients to notify
Added paragraph to High Value Accounts.

published amendments

Miscellaneous: Non-Financial Entity
Admendment of 'or' to 'and' in the opening section of the first bullet point.

published amendments

Due Diligence: Entity Accounts: Investment Entity with Regularly Traded Securities
Under the FATCA and CDOT IGAs, an equity or debt interest in an Investment Entity that is regularly traded on an established securities market is not a Financial Account. The revised page explains the meaning of ‘regularly traded’ in this context.

published amendments

Reportable Information: Reportable Jurisdictions
Removed "Switzerland" from 2017 CRS reporting jurisdictions.

published amendments

Notification requirement: Specified Financial Institutions: Which clients to notify
Added third paragraph under "Other Financial Institutions".

published amendments

Action 5 rulings: Example of exchange of a ruling
updated JITSIC email address
What is a ruling: Transactions that are not carried out in accordance with the ruling
updated JITSIC email address
Exchange of tax rulings: Refusal to provide a ruling
JITSIC email address updated
Exchange of tax rulings: Information not to be exchanged
updated JITSIC email address
What and how to exchange: Overview
updated JITSIC email address
What and how to exchange: Template for exchange of tax rulings
added JITSIC mailbox address
What and how to exchange: How to exchange a ruling
updated JITSIC mailbox
Investment Entity: Introduction
Clarified guidance on direct interests in real property.

published amendments

Charities: Debt or equity interests in a company
Minor change to correct typo in name of Scottish CIO
Charities: Financial Institution
Added links to guidance for trustee documented trusts and FI residence.

published amendments

Notification requirement: Controlled persons overseas: Obligation on overseas persons
Changes include clarification that where overseas persons are not controlled by UK persons which are Specified Financial Institutions or Specified Relevant Persons, the client notification obligations do not apply.

2017

published amendments

Financial Institution: Securitisation Vehicles
Removed obsolete link and amended text
Reportable Information: Tax Identification Number
Inserted paragraph on jurisdictions that do not issue TINs
Financial Institutions: UK Financial Institutions
clarified dual residency treatment for partnerships
Charities: Financial Institution: Examples
Clarification of examples and addition of example 6

published amendments

Charities: Protection on Human Rights Grounds: Contents
republish
Automatic exchange of financial accounts information
-
Add new section IEIM40600 Human Rights
Added 406000 to subpages
Charities: Financial Institution: Examples
Fixed typo in example 6
Financial Institutions: Contents
Added new content IEIM400845 Branches of Specified Insurance Companies

published amendments

Charities: Contents
Removed IEIM404990, superseded by IEIM406000.

published amendments

Charities: Human Rights: Application for redaction
Added link to Schema guidance for information on how to obtain AEOI User ID

published amendments

Exchange of tax rulings: Different obligations
added hyperlinks, altered "key driver" in reference to BEPS project to "leading supporter" per Richard X Thomas' instructions
Exchange of tax rulings: Overview
added hyperlinks

published amendments

What and how to exchange: Template for exchange of tax rulings
Text redaction reapplied.
Rulings template added and guidance updated to reflect.

published amendments

Charities: Human Rights: Application for redaction
Application for redaction PDF added as an attachment.
Charities: Human Rights: Checklist for applications for redaction
Checklist added as a downloadable PDF.

published amendments

Reportable Information: Reportable Jurisdictions
Amendment to reportable jurisdiction list to remove Trinidad and Tobago from jurisdictions reportable in 2017.

published amendments

Notification requirement: Specified Financial Institutions: Which clients to notify
The link to "participating jurisdiction" was corrected.

published amendments

Automatic Exchange of Information: background: contents
-
-
Add link to IEIM400090 participating jurisdiction list
Automatic exchange of financial accounts information
-
Background: Common Reporting Standard
Update link to participating jurisdiction list at IEIM400090

published amendments

Country-by-Country reporting: Contents
Amend title
Country-by-Country reporting: OECD guidance
Correcting email address

published amendments

Common Reporting Standard: Participating Jurisdictions
Amendment to participating jurisdictions list

published amendments

What and how to exchange: Template for exchange of tax rulings
Republish for redaction
Republish for redaction
Republish for redaction
Republishing to fix redaction
republish page
republish page

published amendments

What and how to exchange: Template for exchange of tax rulings
Republish for redaction

published amendments

Country-by-Country reporting: OECD guidance
Correct email address

published amendments

Charities: Human Rights: Application for redaction
Attachment removed and hyperlink added.
Charities: Human Rights: Checklist for applications for redaction
Attachment removed and hyperlink added.

published amendments

Action 5 rulings: Meaning of related party
Updates to letters in example to repair typographical errors.

published amendments

Reportable Information: Reportable Jurisdictions
2017 CRS Reportable Jurisdictions list updated to remove Barbados, Curacao, and Niue. The guidance notes HMRC's acceptance that reports may still contain data on accounts for these jurisdictions, and that HMRC will deal with such data appropriately.

published amendments

Due Diligence: Pre-Existing Entity Accounts: Reportable Accounts: Self-Certification: Financial Institutions
Link from IEIM403560 corrected to IEIM403360.

published amendments

Country-by-Country reporting: Introduction
Hyperlink
Updated to reflect current workflow.
Exchange of Information: Key Concepts
Updating broken link
Legal framework for exchange: Types of international agreement
Addition of subtitles to more clearly delineate subject areas.
Exchange of information: Types of exchange
Updating to add content list.
Exchange of Information: Other collaboration between tax authorities
Incomplete drafting of this page.
Legal framework for exchange: Types of international agreement: The EU Directive on Administrative Cooperation in Tax: Amendments to the Directive
Added link to CBCR guidance, and made minor typesetting changes.

published amendments

Legal framework for exchange: Types of international agreement: The EU Directive on Administrative Cooperation in Tax: Amendments to the Directive
Adding short title
Legal framework for exchange: Types of international agreement: The EU Directive on Administrative Cooperation in Tax: Other principles of exchange under the Directive
Adding short title
Legal framework for exchange: Types of international agreement: The EU Directive on Administrative Cooperation in Tax: Taxes covered by the Directive
Adding short title
Legal framework for exchange: Types of international agreement: The EU Directive on Administrative Cooperation in Tax
Adding short title
Legal framework for exchange: Types of international agreement: The OECD/CoE Multilateral Convention on Mutual Administrative Assistance in Tax Matters: Periods covered
Adding short title
Legal framework for exchange: Types of international agreement: The OECD/CoE Multilateral Convention on Mutual Administrative Assistance in Tax Matters: Taxes covered by the Convention
Adding short title
Legal framework for exchange: Types of international agreement: Tax Information Exchange Agreements
Adding short title
Legal framework for exchange: Types of international agreement: The OECD/CoE Multilateral Convention on Mutual Administrative Assistance in Tax Matters
Adding short title
Legal framework for exchange: Types of international agreement: Double taxation agreements
Adding short title
Repairing links and clarifying taxes covered in the context of a DTA.
Legal framework for exchange: Types of international agreement: Overview
Adding short title
Exchange of information core guidance
Repairing typographical error.
Automatic exchange of financial accounts information
Clarifying in the title that this section of the manual refers to automatic exchange of financial account information, as there are now other sections to the IEIM dealing with other forms of automatic exchange.
Exchange of information: Introduction
Correcting content for the page.
Legal framework for exchange
Adding content list.

published amendments

Exchange of information: Types of exchange: Automatic
Adding short title
Exchange of information: Types of exchange: On request
Adding short title
Exchange of information: Types of exchange: Overview
Adding short title
Exchange of information: Types of exchange
Adding short title
Legal framework for exchange: Types of international agreement: The EU Directive on Administrative Cooperation in Tax: Mandatory exchange
Updating contact details and adding short title.
Exchange of Information: Taxes covered in this guidance
Repairing broken link
Legal framework for exchange: What we can use the information for –taxes covered
Removing erroneous link
Legal framework for exchange: Overview
Repairing broken link
Legal framework for exchange: What we can exchange
Repaired hanging links.

published amendments

Exchange of Information: Inward requests
Repairing broken links.
Due Diligence: Pre-Existing Individual Accounts: Lower Value Accounts: Hold Mail or In-Care-Of Address Only
Repairing typographical errors.

published amendments

Country-by-Country reporting: Contents
Structure
Arrangements
Team space
Reformat
Closed off comments option.
Included additional pages
Country-by-Country reporting: Voluntary filing of CbC reports
deletion
Title
Country-by-Country reporting: Exceptions to the filing obligation
title
reference
Country-by-Country reporting: Notification requirements
title
Country-by-Country reporting: OECD 2020 review of CbC reporting
title
Country-by-Country reporting: Penalties
title
Country-by-Country reporting: Appropriate use of Country by Country reporting data
title
Country-by-Country reporting: How will HMRC use this information?
title
Country-by-Country reporting: Which countries will HMRC exchange CbC reports with?
title
Country-by-Country reporting: Master and Local files
title
Country-by-Country reporting: Directions relating to how CbC reports will be filed
title
Sentence re-worded
Wording
Country-by-Country reporting: Directions relating to the filing of CbC reports on an XML schema
title
Country-by-Country reporting: Examples of filing and notification obligations
title
Country-by-Country reporting: Directions relating to notification requirements
title
Country-by-Country reporting: UKEs – Directions relating to contents of the CbC reports
title
team space
Country-by-Country reporting: The filing obligation
Title
Title
Country-by-Country reporting: When does it start and what is the deadline for filing?
Title
Country-by-Country reporting: Groups in scope and entities that must report
Title
Text entry
Country-by-Country reporting: OECD guidance
Title
Updated to include current text.
Country-by-Country reporting: Introduction
Title
Updated to current text.

published amendments

Country-by-Country reporting: Directions relating to the filing of CbC reports on an XML schema
spell
short title
title
page reference
page reference
Country-by-Country reporting: Directions relating to how CbC reports will be filed
short title
title
sentence
page reference
page reference
Country-by-Country reporting: Directions relating to notification requirements
short title
title
sentence
page reference
page reference
Country-by-Country reporting: UKEs – Directions relating to contents of the CbC reports
short title
title
page reference
page reference
Country-by-Country reporting: UPEs - Direction relating to contents of the CbC report
short title
title
page reference
page reference
Country-by-Country reporting: Voluntary filing of CbC reports
sentence
page reference
page reference
Country-by-Country reporting: The filing obligation
sentence
sentence
Country-by-Country reporting: When does it start and what is the deadline for filing?
sentence.
Country-by-Country reporting: Penalties
page reference
page reference
Country-by-Country reporting: OECD 2020 review of CbC reporting
page reference
page reference
Country-by-Country reporting: Appropriate use of Country by Country reporting data
page reference
page reference
Country-by-Country reporting: Master and Local files
page reference
page reference
Country-by-Country reporting: How will HMRC use this information?
page reference
page reference
Country-by-Country reporting: Which countries will HMRC exchange CbC reports with?
page reference
page reference
Country-by-Country reporting: Examples of filing and notification obligations
page reference
page reference
Country-by-Country reporting: Exceptions to the filing obligation
page reference
page reference

published amendments

Country-by-Country reporting: Exceptions to the filing obligation
Upate to para 2
Country-by-Country reporting: The filing obligation
Last para

published amendments

Country-by-Country reporting: Directions relating to notification requirements
Minor change to administrative instructions for coherence.

published amendments

Reporting Format
Removal of obsolete paragraph.

published amendments

Legal framework for exchange: Underlying Agreements: Multilateral Competent Authority Agreements
Broken links repaired.
Legal framework for exchange: Types of international agreement: The EU Directive on Administrative Cooperation in Tax: Mandatory exchange
Broken links repaired.
Legal framework for exchange: Types of international agreement: The EU Directive on Administrative Cooperation in Tax: Amendments to the Directive
Broken link repaired.
Broken link repaired.
Legal framework for exchange: Types of international agreement: Tax Information Exchange Agreements
Broken link repaired.
Legal framework for exchange: What we can use the information for –uses other than tax
Broken link repaired.
Exchange of Information: Key concepts: Jurisdictions that the UK can exchange with
Broken link repaired.
Broken links repaired.
Exchange of Information: Joint audits
Broken links repaired.
Exchange of Information: Inward requests
Broken link repaired.
Exchange of Information: Inward spontaneous information
Broken links repaired.
Exchange of Information: Outward requests: What can I tell the customer?
Broken link repaired.
Repaired broken links.
Exchange of Information: Outward requests: Risk assessment
Broken link repaired.
Exchange of Information: Outward requests: General information
Broken links repaired.
Exchange of information: From another jurisdiction to the UK: Overview
Broken links repaired.
Exchange of information: Types of exchange
Broken link repaired.
Exchange of information: Types of exchange: Automatic
Repair broken link.
Exchange of information: Types of exchange: On request
Broken link repaired.
Exchange of Information: Key concepts: Foreseeable relevance and ‘Fishing expeditions’
Broken link repaired.
Exchange of Information: Key concepts: Foreseeable relevance
Broken links repaired.
Broken links repaired.
Exchange of Information: Key concepts: Legal gateways
Broken links repaired.
Exchange of Information: Key Concepts
Broken links repaired.
Broken links repaired.
Exchange of information: Purpose of the guidance
Broken links repaired.
Exchange of information: Introduction
Repaired broken links.