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HMRC internal manual

Shares and Assets Valuation Manual

HM Revenue & Customs
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Other compliance matters: Exchange of information with an overseas tax authority

Valuers may encounter situations where an exchange of information with an overseas tax authority may be of benefit either to HMRC or to that overseas tax authority.

Examples may include situations involving the disposal of shares and other assets by non-UK residents or transactions involving assets located abroad.

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.

Such exchanges may take place under Double Taxation Agreements or a variety of different instruments - bilateral and multilateral agreements as well as EU Directives and Regulations.

Exchanges may only take place between authorised officers of the Board and authorised officers of the government of the other territory. These officers are often referred to as “competent authorities”.

The International Manual at INTM156000 onwards contains guidance on how information may be sought from or provided to overseas tax authorities. In particular, the format for a request for information is at INTM156060. Please note that information exchanges with regard to inheritance tax should be directed through IHT Technical Group at Trusts and Estates.

SAV’s Litigation and Technical Advice Team is ready to provide any assistance that valuers may require in this connection.

  Additional Guidance: SVM150000