Bilateral information exchange agreements

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.

While multilateral agreements have grabbed most of the headlines HMRC and its counterparts have made huge inroads in using the potential of existing bilateral protocols.

Automatic exchange of information

In recent years the scale of co-operation between the financial world and the world’s tax authorities has changed beyond all recognition. The most conspicuous manifestation is the development of automatic exchange of information agreements which began with the US Foreign Account Tax Compliance Act (FATCA) in 2010.

FATCA is a US federal law which uses the weight of US power and its de facto control of the...