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HMRC internal manual

International Manual

From
HM Revenue & Customs
Updated
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Exchange of information: General

The exchange of information between HMRC and tax authorities in other territories is an essential tool in enabling authorities both to administer and enforce their own taxes and to combat avoidance and evasion. The importance of effective exchange of information has increased over the years as international trade barriers have come down and capital has become more mobile.

The UK has exchanged tax-related information under Double Taxation Agreements for many years for the purposes outlined above. However, there is now a variety of different instruments - bilateral and multilateral agreements as well as EU Directives and Regulations - through which HMRC can assist other tax authorities and seek assistance from them in relation to both direct and indirect tax liabilities.

These include:

  • Double Taxation Agreements.
  • Tax Information Exchange Agreements.
  • The joint Council of Europe/OECD Multilateral Convention on Mutual Administrative Assistance in Tax Matters.
  • Directive 77/799/EEC concerning mutual assistance by the competent authorities of the Member States of the EU in the field of direct taxation and taxation of insurance premiums.
  • Regulation (EC) No 1798/2003 concerning administrative cooperation by the EU Member States in the field of value added tax.
  • Regulation (EC) No 2073/2004 concerning administrative cooperation by the EU Member States in the field of excise duties.
  • Directive 2008/55/EC on mutual assistance by the EU Member States for the recovery of claims relating to certain levies, duties, taxes and other measures.

Exchange of information with other EU Member States under the EC Regulation 1798/03 (VAT administrative co-operation) is dealt with by the UK VAT Central Liaison Office. HMRC readers may consult the relevant intranet guidance for further information.

Exchange of information with other EU Member States under the EC Regulation 2073/04 (administrative co-operation in excise) is made by the UK Excise Central Liaison Office (CLO), or by any Liaison Department or Competent Officials authorised by the Excise CLO to exchange information directly. For further information, consult the guidance in the Introduction to Administrative Co-operation in Excise (INACE) manual which is available on both the internal and public HMRC websites.

The instructions on the following pages apply to all direct tax exchanges of information and indirect tax exchanges with countries other than EU Member States.