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HMRC internal manual

International Manual

HM Revenue & Customs
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Double Taxation applications and claims - Exchange of information and correspondence with overseas tax authorities: Provisions in Double Taxation Agreements

Exchange of information provisions in Double Taxation Agreements

The background to the exchange of information provisions in Double Taxation Agreements (DTAs) is explained at INTM153280.

In the UK, the ‘competent authority’ means the Commissioners of HM Revenue & Customs or their authorised representative. In practice, Business International, Outward Investment Team is the competent authority and most of the competent authority functions concerning claims made under DTAs by overseas residents have been delegated to Personal Tax International. However, Business International, Outward Investment team will carry out all correspondence in the following categories

  • the mutual agreement procedure (see INTM153270)
  • where there is a primary policy interest on a matter of interpretation of the DTA