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HMRC internal manual

Technical Teams Operational Guidance

Code of Practice 8: particular types of Code of Practice 8 cases: exchange of information referrals

A lot of important Code 8 cases have been identified from Exchange of Information referrals and this is both an important and useful source of information. Whilst Code 8 can be appropriate in many of these types of cases, the Investigator may consider that the case is more appropriate to be considered under Code 9.

As with any review case, it is important that the case be brought to the appropriate standard before registration is approved. It can often be difficult to ascertain whether it is HMRC or a foreign fiscal authority that is losing from the arrangements which have been apparently put in place.

If there is not sufficient confidence to proceed to registration, there are effectively three options:

  • refer back to the foreign Revenue Authority with a request for further information clarification
  • to approach the UK taxpayer whilst the case is still a review, though this will be the exception (see TTOG3470).
  • close down the SI interest.