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The provision of information by one tax authority to another: lessons from Chatfield

Good friends should help each other? Jonathan Peacock QC (11 New Square) examines the provision of tax information by HMRC to a foreign tax authority in light of a robust decision in a long running battle in New Zealand.
 

With the globalisation of trade and the increasing ‘internationalisation’ of both tax disputes and tax compliance it is no surprise that cooperation between tax authorities around the world is increasing in scope to ensure the detailed and timely provision of information about taxpayers by one jurisdiction to another. The UK is a party to many agreements by which information can be provided by one state to another. These include for example the Mutual Assistance Directive (originally 1977/799/EEC and now a part of 2011/16/EU) the Mutual Assistance Recovery Directive (originally 2008/55/EC and now 2010/24/ EU) the Directive on Administrative Cooperation in the Field of Taxation (DAC) (Directive...

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