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Seeing the broader picture: HMRC’s information exchange powers and obligations

Tax authorities have access to more sources of information than ever before. Mark Whitehouse and Miranda Edwards (PwC) explore recent developments in HMRC’s international and domestic information powers and consider the implications for multinationals.

Increased complexity and mobility of cross-border business and finance and the need to combat tax avoidance has led to an increased focus by tax authorities on information exchange. This is echoed in HMRC’s International Exchange of Information Manual at IEIM100010 which states that information exchanges are ‘an essential way of increasing tax transparency and cooperation between jurisdictions’. In this article we consider the various routes (domestic and international) which HMRC may pursue to ensure it is in a position to evaluate international business transactions holistically.

International routes

The increased focus on the use of information exchange is best illustrated by the UK’s recent implementation of the following measures which have further expanded...

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