
Ihtm27163 - foreign property: double taxation conventions: exchange of information: why exchange information? - hmrc internal manual
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IHTM27163 - FOREIGN PROPERTY: DOUBLE TAXATION CONVENTIONS: EXCHANGE OF INFORMATION: WHY EXCHANGE INFORMATION? One of the purposes of Double Taxation Conventions is to provide rules for
exchanging relevant information between the two contracting countries. To exchange information, we must send a bulletin (form 730 - IHTM27164) detailing the assets on which the other
country might have a claim. What information is provided in the bulletin depends largely on the domicile (IHTM13001) or residence of the deceased. Remember that this applies not only when
someone becomes beneficially entitled to property following a death but also when they get a capital distribution from a settlement (except in the case of exchanges with France, Italy and
Switzerland). Convention partners will send us bulletins to notify us that we may have a claim to tax, for example, F2092 from the USA, or CA52 from Ireland. Where specific information
is required from a foreign taxation authority that has a Double Taxation Convention with the UK, Technical may be able to obtain it by writing directly to the foreign taxation authority.
This also applies where foreign taxation authorities have a TIEA (Tax Information Exchange Agreement) with the UK or where the country concerned is a signatory to the OECD Convention on
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