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HMRC internal manual

International Manual

Exchange of information: Spontaneous exchanges

Information is exchanged spontaneously when one country obtains information which it considers will be of interest to another country and passes it on without having received a request. Information of this sort received in the United Kingdom is evaluated by the Risk & Intelligence Service Offshore Risk Team and sent to the appropriate office for action.

HMRC staff should be alert to opportunities for providing information spontaneously to overseas tax authorities. The types of information that may be helpful to other countries are very wide ranging, but as a guideline, information should be provided because of its general importance or because of the amount of tax involved. In particular, information suggesting that the tax laws of another country may have been abused or that tax has been evaded or avoided should be provided. The information should be as accurate and complete as possible and should be sufficient to enable the overseas tax authority to trace their taxpayer. Any available corroborative evidence and documents should be provided. Except in the cases referred to below, the Centre for Exchange of Intelligence (CEI) is responsible for passing the information to the overseas tax authorities and will decide whether it is within the scope of the relevant agreement and appropriate to send. It is therefore important that any matters of a potentially sensitive nature are brought to the attention of the CEI.

Where the information relates to aggressive or abusive tax avoidance schemes with an Australian, Japanese, Korean, Canadian or American connection, any report should be made to the JITSIC team at CSTD Business, Assets & International.

Where a transaction comes within Part 4 (Transfer Pricing: sections 146-217) of the Taxation (International and Other Provisions) Act 2010 (TIOPA 2010) any report should be made to CSTD Business, Assets & International, to whom reports should also be made where there is any information to suggest significant avoidance of foreign tax by a multi-national group.