Bilateral information exchange agreements

Key points

• The existing bilateral information exchange agreements between HMRC and key counterparts have a very wide scope.
• HMRC is working closely with its counterparts to realise far more of their potential and to form international groupings.
• The growing significance of bilateral agreements is easily overlooked with all the focus on CRS and FATCA.
• Unlike CRS and FATCA information is normally exchanged in secrecy with no taxpayer knowledge and need follow no prescribed format.
• Information sharing arrangements are ‘hard-wired’ into conventional double tax treaties.
• The UK also has many TIEA exchange agreements with former high secrecy jurisdictions.

With all the developments in the automatic multilateral exchange of information over the past ten years it is perhaps easy to overlook the powerful and longstanding potential for HMRC and its counterparts to exchange information bilaterally. Such information is not restricted to any prescribed format and is normally exchanged secretly from the taxpayer....