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.