SDLTM80280 - Compliance: Liaison

Special Compliance Office (SCO): Exchange of information with overseas tax authorities

SCO Intelligence, Angel Court, 199 Borough High Street, London SE1 1HZ is responsible for the majority of exchanges of information with overseas tax authorities under the provisions of our Double Taxation Agreements and the EC Mutual Assistance Directive.

Detailed guidance is given in the Double Taxation Relief Manual at DT233 and DT350.

If it is considered that information from an overseas tax administration will assist in an enquiry, SCO Intelligence can make a formal request on their behalf.

Requests for information should not be made unless there is a specific reason for requiring the information and all other avenues for obtaining the information have been exhausted.

Before asking a foreign tax authority for assistance a caseworker should normally have tried to obtain the information themselves. For example, if a information is received that a purchaser has assets abroad the compliance caseworker should normally have put their concerns to the purchaser and asked them for explanations and evidence before considering a request to the overseas tax authority.

Requests can be costly, so should usually be made for the most important cases only.

SCO Intelligence can give advice on whether it is appropriate to request information from overseas.

Requests to SCO Intelligence should be in the format in DT355.

SCO Intelligence also sends information spontaneously to foreign tax authorities. If, rather than requesting information, it is felt that information discovered during an investigation could be of value to a foreign tax authority a report should be sent to SCO Intelligence, together with the compliance caseworker’s file.