Income Tax Treaties: Competent Authority Functions and Procedures of Selected Countries (O-Z) (Portfolio 6895)

Tax Management Portfolio, Income Tax Treaties: Competent Authority Functions and Procedures of Selected Countries (O–Z), No. 6895, discusses the competent authority functions and procedures of Russia, Spain, Sweden, Switzerland and the United Kingdom. To view this Portfolio, visit Bloomberg Tax for a free trial.

Bloomberg Tax

This Portfolio is available with a subscription to Bloomberg Tax, a comprehensive research solution including over 500 Tax Management Portfolios™, practice tools, primary sources and timely news.

Description

Tax Management Portfolio, Income Tax Treaties: Competent Authority Functions and Procedures of Selected Countries (O–Z), No. 6895, discusses the competent authority functions and procedures of Russia, Spain, Sweden, Switzerland and the United Kingdom. Each chapter initially focuses on the mutual agreement procedure that is available to taxpayers subject to double taxation, and in that connection discusses such topics as the basic procedure for requesting competent authority relief, statute of limitations issues, the role of Appeals (if any), the small case procedure (if any), interest on deficiencies and refunds, and the possibility of arbitration. If a country also has procedures for Advance Pricing Agreements, those are also considered.

Each chapter then discusses the procedures relating to consultation between competent authorities regarding the interpretation or application of an income tax treaty, exchange of information, and assistance in collection. With respect to exchange of information, each chapter also considers procedures under any tax information exchange agreements to which the country is a party.

For competent authority functions and procedures of the United States, see 940 T.M., Income Tax Treaties: Competent Authority Functions and Procedures of Selected Countries (O–Z).

This Portfolio may be cited as Alekseyev, et al., 6895 T.M., Income Tax Treaties: Competent Authority Functions and Procedures of Selected Countries (O–Z).

Authors

Maxim Alekseyev, Esq.

Maxim Alekseyev is a co-founder and senior partner of ALRUD, head of ALRUD Tax and Private Clients Practices. He is a graduate of the Moscow State Institute of International Relations of the Ministry of Foreign Affairs of the Russian Federation. Mr. Alekseyev is an expert on matters relating to foreign economic and business activities, investments, as well as corporate and commercial issues, and leads on projects dealing with Russian and foreign partners. In his private client practice, Mr. Alekseyev has extensive experience advising ultra-high net worth individuals on various types of issues, including assistance with asset protection and family law. He advises clients on different aspects of estate planning and administration, personal wealth management, family governance, and risk management. Mr. Alekseyev is recognized in matters relating to domestic and international tax projects (including resolution of tax disputes), wealth planning (e.g., assistance with succession planning via the use of onshore and offshore tax structures), private banking and individual taxation. Mr. Alekseyev is a member of the International Bar Association (IBA), the American Bar Association (ABA), the Inter-Pacific Bar Association (IPBA) and the Society of Trust and Estate Practitioners (STEP). He regularly participates in international professional events regarding issues of investment and taxation, and provides expert opinion on international tax issues for the leading Russian and international media. He is also a frequent speaker at foreign and domestic conferences and seminars. In 2016, Chambers HNW, recognized Mr. Alekseyev as a leading expert in Private Wealth Law Services. Tax Directors Handbook and the Who's Who Legal CIS (2010) recognize Mr. Alekseyev as a “highly regarded” Senior Partner. In addition, Best Lawyers, 2015 & 2017 recommends Maxim Alekseyev for Corporate law and M&A. Russia's Best Lawyers 2013 edition recommends Maxim Alekseyev as one of the best lawyers in the field of Mergers and Acquisitions. The European Legal Experts 2013 recommend Maxim Alekseyev for Corporate and M&A law and Tax. Tax Directors Handbook appreciates Maxim Alekseyev as “highly regarded senior partner.” Who's Who Legal, 2013 recommends Maxim Alekseyev for Corporate Tax.

Pere M. Pons, Esq.

Pere M. Pons is a lawyer in the Tax Practice Area of the Spanish law firm Uría Menéndez. He joined the firm in 2006 after having worked for five years in another prestigious firm based in Barcelona. Since 2010, he has headed the Tax Practice of the firm's New York office. Pere specializes in international taxation, regularly advising on the tax planning of international investment structures in Spain and Latin America, as well as operations of hedge funds and private equity entities in Spain and abroad. He also advises on the tax implications in Spain of financing structures, swaps, and financial products, and on Spanish investments abroad. Pere has extensive experience in real estate and distressed debt investments, as well as tax planning for tax consolidated groups and subsidiaries of multinational companies. He also regularly assists high net worth individuals and family offices, and has advised on the regularization of offshore investments and excessive debt push-down structures (including legal defense in tax audits and courts of justice). He has also advised government agencies and individuals on the prevention of money laundering and on foreign investment regulations. Before joining Uría Menéndez's New York office, Pere was involved in the implementation of the OECD international standard on exchange of information in the new tax framework of the Principality of Andorra. He was also involved in Moneyval's (Council of Europe) assessment (based on the FATF-GAFI standards) of the Andorran legislation on the fight against money laundering and the financing of terrorism. Pere is a regular speaker at seminars and conferences. Before moving to New York, he was a lecturer in the International Taxation Course organized by the Spanish Tax Advisors Association. He has also authored a number of articles and publications.

Andrés Espinós, Esq.

Andrés Espinós Alegre is a Spanish lawyer specializing in the taxation of corporate entities and individuals, both tax residents and nonresidents in Spain. He regularly advises on tax planning for M&A transactions and on the tax structuring of Spanish investments abroad and foreign investments in Spain. He is also involved in litigation and tax audit matters. In the last few years, he has focused his practice on exchange of information matters, and has advised several Spanish and Andorran clients on the implementation of the OECD international standard in this area, as well as on setting up a new tax framework in the Principality of Andorra. He has also been closely involved in the assessment by Moneyval (Council of Europe) of the Andorran legislation on the fight against money laundering and the financing of terrorism. Andrés is also a lecturer in the International Taxation Course organized by the Spanish Tax Advisors Association.

Niklas Bång, Esq.

Niklas Bång (Master of law, Lund University) is the deputy managing partner of Skeppsbron Skatt. Niklas has been with Skeppsbron Skatt since its establishment of offices in Malmo in 2005, and before that he was employed by Ernst &Young International Tax. Publications include Svensk Skattetidning (Swedish professional tax journal) and IBFD: Derivatives and Financial Instruments. Niklas is also co-author of the Swedish section of Getting the Deal Through: Tax on Inbound Investment. Niklas is the national reporter of Sweden for the American Bar Association, and the Swedish member of the Bloomberg Tax Treaties Analysis Editorial Board.

Mikael Jacobsen, Esq.

Mikael Jacobsen (Master of law, Jönköping University) is a transfer pricing and international tax specialist of Skeppsbron Skatt. Mikael joined Skeppsbron Skatt in 2009, and before that he was employed by Deloitte. Publications include Svensk Skattetidning (Swedish professional tax journal) and Tax Planning International Transfer Pricing (BNA).

Jacqueline Hess

Jacqueline Hess holds a B.A. from the University of Chicago, a J.D. from Cornell Law School, and an LL.M. in International Taxation from Catholic University, Louvain, Belgium. She is the Managing Partner, Tax & Legal, of Deloitte, Switzerland. She is a member of the Tax Chapter Board of the Swiss-American Chamber of Commerce, as well as the Swiss Advisory Board of the American Swiss Foundation. Ms. Hess regularly lectures on international tax subjects in Europe and in the United States.

Raoul Stocker

Raoul Stocker holds a Ph.D. Degree in Law from the University of St. Gallen and a Master in Business Administration from the University of Bern. He is an Assistant Professor at the University of St. Gallen in the field of taxation and a Tax Partner at Deloitte, Switzerland. From 2003 to 2008, Mr. Stocker was the Head of Transfer Pricing at the Swiss Federal Tax Administration, where he was responsible for MAP and APA negotiations in transfer pricing matters. Mr. Stocker is a Certified Swiss Tax Expert.

Véronique Parmentier

Véronique Parmentier holds a law degree from the University of Liège, Belgium, an LL.M. in International Trade Law from the University of Essex in the United Kingdom, and a Master in Taxation from HEC in Liège, Belgium. She is an International Tax Director at Deloitte, Switzerland, and is a member of the Belgian Institute of Tax Advisors.

Christopher Harrison, Esq.

Christopher Harrison has been a tax partner in the London office of Allen & Overy LLP since 2004. Mr. Harrison advises on bank taxation and on the tax aspects of financing transactions (including securitisations and international capital markets issuances) and corporate transactions (including mergers, acquisitions, joint ventures, and reconstructions).

Steve Quinn, Esq.

Steve Quinn is a tax associate in the London office of Allen & Overy LLP and advises on all areas of the tax department's practice.

Table of Contents

Detailed Analysis
Chapter 140 — RUSSIA
140:I. Introduction
A. In General
B. Provision for Mutual Agreement in Russia's Income Tax Treaties
1. Comparison to the OECD Model
2. Variation Among Russia's Income Tax Treaties
3. Other Agreements
140:II. The Competent Authority of the Russian Federation
A. The Ministry of Finance
B. The Federal Tax Service
140:III. Mutual Agreement Procedure for Taxpayer Cases
A. In General
1. Historical Background
2. Powers of Competent Authorities in a MAP
3. Possibility of Taxpayer-Initiated Adjustments
4. Reasons for Refusing a MAP Request
B. The Procedure
1. Sources of Official Information on the Procedure
2. Taxes and Issues Covered
3. Who Can Apply?
4. Timing of Requests
5. Information Required
6. Denial of Requests
7. Processing of MAP Cases
a. Examination of the Taxpayer's Claim
b. Negotiation
c. Decision on the Taxpayer's Claim
8. Arbitration
140:IV. Advance Transfer Pricing Agreements
A. Introduction
B. Who can Conclude an APA?
C. Statistics on APA Cases
D. Scope of APAs
E. Duration of APAs and Retroactive Effect
F. Time Frame for the Process
G. Pre-Filing Meeting
H. Preparation and Filing
I. Evaluation of APA Application
J. Documentation Requirements
K. Communications Between Competent Authorities
1. Preliminary Discussion with the FTS
2. Formal Application
3. FTS's Consideration of the Taxpayer's Application
4. Negotiations Between Competent Authorities
5. Implementation of the Mutual Agreement of the Competent Authorities
6. Non-Conclusion of the Bilateral APA
L. Compensating Adjustments
M. Withdrawing from APA Process
N. Monitoring of APA Execution
O. Renewal of an APA
P. Small Business APAs
140:V. Consultation Between Competent Authorities Regarding Treaty Interpretation or Application
A. In General
B. Scope of Consultation
C. Consultation Procedure
D. Legal Effect of Consultations
140:VI. Exchange of Information
A. In General
B. Exchange of Information Under Income Tax Treaties
1. Scope of Treaty Provisions
a. Taxpayers and Taxes Covered
b. Nature of Information
2. Types of Exchange
a. In General
b. Automatic Exchange of Information
c. Spontaneous Exchange of Information
d. Specific Request for Information
3. Simultaneous Examination Programs
4. Restrictions on the Use and Disclosure of Exchanged Information
C. Exchange of Information Under Tax Information Exchange Agreements
1. Taxpayers Covered
2. Taxes Covered
3. Nature of Information
4. Types of Exchanges
5. Procedure for Exchanges
6. Limitations in the Agreements
D. Exchange of Information to Facilitate the Implementation of FATCA
E. Exchange of Information Under OECD Council of Europe Convention on Mutual Administrative Assistance in Tax Matters
F. Exchange of Information Under Other International Agreements
140:VII. Assistance in Tax Collection
Introductory Material
A. Assistance in Tax Collection Under Income Tax Treaties
B. Assistance in Tax Collection Under Agreement Between Russia and Uzbekistan
C. Assistance in Tax Collection Under Other International Agreements
1. Agreement between CIS members
2. Agreement Between EAEU Members
Chapter 150 — SPAIN
150:I. Introduction
A. In General
B. Provisions for Mutual Agreement in Spanish Income Tax Treaties
1. Comparison to the OECD Model
2. Variations Among Spanish Income Tax Treaties
150:II. The Competent Authority in Spain
A. Identification
B. Functions in General
150:III. The Mutual Agreement Procedure for Taxpayer Cases
A. In General
1. Historical Background
2. Powers of the Competent Authority in a MAP
3. Possibility of Taxpayer-Initiated Adjustments
4. Statistics on MAP Cases
B. Types of Cases
1. Allocation Cases
2. Non-Allocation Cases
C. The Procedure
1. MAP Cases Initiated with the Spanish Competent Authority Due to Spanish Tax Authority Actions
a. Taxes Covered
b. Who Can Apply?
c. Filing Term
d. Pre-Filing and Post-Filing Conferences
e. Application and Documents to Be Provided
f. Initiation of a MAP
g. Denial of a MAP Request
h. Minimum Amount
i. Development of a MAP
j. End of a MAP
k. Withdrawal
l. Appeals
m. Implementation of a MAP Decision
2. MAP Cases Initiated with a Foreign Competent Authority Due to Spanish Tax Authority Actions
3. MAP Cases Initiated with a Foreign Competent Authority Due to Foreign Tax Authority Actions
4. MAP Cases Initiated with the Spanish Competent Authority Due to Foreign Tax Authority Actions
5. Timing of Requests, Statute of Limitations, and Other Limitations
6. Unilateral Relief
7. Protective Measures
8. Small Case Procedure
9. Effect on Domestic Proceedings
10. Court Proceedings
11. Confidentiality in Competent Authority Proceedings
a. Confidentiality of Returns and Return Information
b. Communication of Taxpayer Information Between Competent Authorities
c. Non-Disclosure by Competent Authorities
12. Interest on Tax Refunds
13. Prior Interest, Penalties, and Legal Surcharges
14. Repatriation of Funds After Reallocation and Secondary Adjustment
15. Accelerated Competent Authority Procedure
D. Arbitration
1. Provisions in Spain's Income Tax Treaties
2. Arbitration Procedures Under Other International Agreements to Which Spain Is a Party
a. The MAP as a Preliminary Stage: Differences from the MAP in Tax Treaties
b. The Arbitration Phase
150:IV. Advance Pricing Agreements
A. Introduction
B. Statistics
C. Scope of AVAs and APAs
D. Procedure and Duration
1. AVAs
2. APAs
E. APAs Not Involving Foreign Tax Authorities
1. Pre-Filing Meetings and Other Pre-Filing Steps
2. Initiation of Proceedings
3. Grounds to Reject an APA Request
4. Confidentiality and Use of Filed Documentation
5. Case Management Plan and Processing
6. Duration of the APA Process
7. End of the APA Process and Decision
8. Withdrawal from the APA Procedure
9. Review and Penalties
10. Appeals Against the APA Decision
11. Follow-Up Information
12. Amendment of the APA
13. Extension of the APA
F. APAs Involving Foreign Tax Authorities
1. Initiation of Proceedings
2. Processing and Resolution
3. Request for an APA Received from a Foreign Tax Authority
G. Effectiveness and Retroactive Effect
H. Small Business APAs
150:V. Consultation Between Competent Authorities Regarding Treaty Interpretation or Application
A. General Comments
B. Scope of Consultation
C. Consultation Procedure
D. Legal Effect of Consultations
150:VI. Exchange of Information
A. In General
1. Exchange of Information Outside of International Agreements
2. Exchange of Information Under International Agreements
B. Exchange of Information Under Income Tax Treaties
1. Scope of Treaty Provisions
a. Competent Authority
b. Taxpayers Covered
c. Taxes Covered
d. Nature of Information
2. Types of Exchanges
3. Simultaneous Examination Programs
4. Responding to Specific Information Requests Under Tax Treaties
a. Specificity of Request
b. Use of Revenue Powers to Obtain Information
c. Mutuality Clause
d. Business Secrets
5. Restrictions on Use and Disclosure of Exchanged Information
a. Use for Tax Purposes Only
b. General Restrictions on Disclosure
c. Nondisclosure to Spanish Legislative Bodies
d. Nondisclosure to Third Countries
C. Tax Information Exchange Agreements
1. Taxes Covered
2. Types of Exchanges
3. Procedure for Exchanges
4. Limitations in the Agreements
5. Retroactive Application of EOI
D. Exchange of Information Under Other International Agreements
1. Council Directive 2011/16/EU of February 15, 2011, on Administrative Cooperation in the Field of Taxation
2. OECD and Council of Europe Convention on Mutual Administrative Assistance in Tax Matters
3. Multilateral Competent Authority Agreement on Exchange of Financial Account Data
E. Exchange of Information Under FATCA IGA Concluded with the United States
1. Introduction
2. Implementation of the FATCA IGA in Spain
E. Exchange of Information Under the CRS
1. Introduction
2. Implementation of the CRS in Spain
150:VII. Assistance in Tax Collection
Introductory Material
A. Council Directive 2010/24/EU of March 16, 2010, Concerning Mutual Assistance for the Recovery of Claims Relating to Taxes, Duties, and Other Measures
B. Assistance in Tax Collection Under Income Tax Treaties
C. OECD and Council of Europe Convention on Mutual Administrative Assistance in Tax Matters
Chapter 155 — SWEDEN
155:I. Introduction
A. In General
B. Comparison to the OECD Model Treaty
155:II. The Competent Authority of Sweden
155:III. The Mutual Agreement Procedure for Taxpayer Cases
A. In General
B. Types of Cases
C. The Procedure
1. Sources of Official Information on the Procedure
2. Taxes and Issues Covered
3. Who Can Apply?
4. Timing of Requests
5. Unilateral Relief
6. The Role of Appeals
7. Pre-Filing and Post-Filing Conferences
8. Information Required
9. Simultaneous Appeals Procedure
10. Denial of Requests
a. Basis for Denial
b. Appeal Rights
11. Processing of MAP Cases
a. Stages of Procedure in Sweden
(1) Examination of the Taxpayer's Claim
(2) Preparation of Sweden's Position
(3) Negotiation
(4) Decision on the Taxpayer's Claim
b. Withdrawal of MAP Request
c. Court Proceedings
12. Confidentiality in Competent Authority Proceedings
a. Confidentiality of Returns and Return Information
b. Communication of Taxpayer Information Between Competent Authorities
13. Penalties
D. Arbitration
1. Provisions in Income Tax Treaties
2. Arbitration Procedures Under Other International Agreements to Which Sweden Is a Party
155:IV. Advance Pricing Agreements
A. Introduction
B. Scope of APAs
C. Duration and Retroactive Effect
D. Pre-Filing Meeting
E. Preparation and Filing
F. Documentation Requirements
G. Requirement of Notification
H. Modification or Revocation of an APA
155:V. Exchange of Information
A. Introduction
B. Exchange of Information Under FATCA IGA Concluded with the United States
1. Introduction
2. Implementation of the FATCA IGA in Sweden
C. Exchange of Information Under the CRS
1. Introduction
2. Implementation of the CRS in Sweden
155:VI. Assistance in Tax Collection
Chapter 160 — SWITZERLAND
160:I. Introduction
160:II. The Swiss Competent Authority
A. Functions in General
B. Identification
160:III. The Mutual Agreement Procedure in Taxpayer Cases (MAP)
A. Treaty Provisions on Mutual Agreement
1. OECD Model Treaty
2. Swiss Income Tax Treaties
B. Background
1. Historical Background
2. Powers of Competent Authorities in a MAP
C. The Process
1. Sources
2. Taxes and Issues Covered
3. Who Can Apply?
4. Timing of Requests
5. The Role of Appeals
6. Pre-Filing and Post-Filing Conferences
7. Information Required
8. Denial of Requests
9. Protective Measures
10. Processing of MAP Cases
a. Stages of Procedure
(1) Examination of the Taxpayer's Claim
(2) Role of the Taxpayer
(3) Consultations with the Other Contracting State
(4) Decision on the Taxpayer's Claim
b. Withdrawal of a MAP Request
c. Effect on Domestic Proceedings
11. Confidentiality in Competent Authority Proceedings
D. Arbitration
1. Background — Swiss Treaties
2. Arbitration Procedure
E. The Impact of BEPS
160:IV. Advance Pricing Agreements
A. Introduction
B. Swiss Approach
C. Legal Framework
D. Swiss Requirements and Procedures
160:V. Consultation Between Competent Authorities Regarding Treaty Interpretation or Application
160:VI. Exchange of Information: Administrative vs. Judicial Assistance
Introductory Material
A. In General
1. Administrative Assistance
B. Exchange of Information Under Income Tax Treaties and Tax information Exchange Agreements
1. Old Procedure
2. New Procedure
3. Procedures Under the U.S.-Switzerland Income Tax Treaty
a. The 1996 U.S.-Switzerland Income Tax Treaty
b. Survey of Developments with Respect to U.S.-Switzerland Administrative Assistance
c. The UBS Agreement
d. The Revised U.S.-Switzerland Income Tax Treaty
e. The DOJ Program for Swiss Banks Involved in Tax Fraud Issues with U.S. Customers
C. The GASI Act: A Unilateral Measure to Adopt the OECD Standard
D. Exchange of Information Under the OECD Council of Europe Convention on Mutual Administrative Assistance in Tax Matters (MAC)
1. Automatic Exchange of Information
a. Automatic Exchange of Information Under the Common Reporting Standard
b. Country-by-Country Reporting
2. Spontaneous Exchange of Information
a. Definition of a Tax Ruling
b. Categories of Tax Rulings Concerned
c. Jurisdictions Receiving Information
d. Time Frame and Deadline Requirements
E. Exchange of Information Under Intergovernmental Agreement to Facilitate the Implementation of FATCA (FATCA Agreement)
F. Exchange of Information Under the Rubik Agreement
G. Judicial Assistance in Tax Matters
1. The U.S.-Switzerland Treaty on Criminal Assistance
2. Federal Act on International Mutual Assistance in Criminal Matters
3. Competent Authority and Procedure
4. Legal Remedies
160:VII. Assistance in Tax Collection
Chapter 175 — THE UNITED KINGDOM
175:I. Introduction
175:II. U.K. Competent Authority
A. Functions in General
B. Identification
175:III. Mutual Agreement Procedure in Taxpayer Cases
A. Treaty Provisions on Mutual Agreement
1. OECD Model Treaty
2. U.K. Income Tax Treaties
B. Background
1. Historical Background
2. Powers of Competent Authorities in a MAP
3. Types of Cases
a. Allocation Cases
b. Nonallocation Cases
4. Program Evaluation
5. Self-Help Alternative
C. The Process
1. Sources
2. Taxes and Issues Covered
3. Who Can Apply?
4. Timing of Requests
a. In General
b. Statute of Limitations and Other Procedural Limitations
(1) In General
(2) Treaty Provisions
(3) Opening Barred Assessment Periods
(4) Keeping Years Open
5. Unilateral Relief
6. The Role of Appeals
7. Pre-Filing and Post-Filing Conferences
8. Information Required
9. Protective Measures
10. Small Case Procedure
11. Simultaneous Appeals Procedure
12. Denial of Requests
a. Basis for Denial
b. Appeal Rights
c. De Minimis Amounts
13. Processing of MAP Cases
a. Stages of Procedure in HMRC
b. Withdrawal of MAP Request
c. Effect on Domestic Proceedings
d. Court Proceedings
14. Confidentiality in Competent Authority Proceedings
a. Confidentiality of Returns and Return Information
b. Communication of Taxpayer Information Between Competent Authorities
c. Nondisclosure by Competent Authorities
15. Interest on Deficiencies and Refunds
16. Penalties
17. Repatriation of Funds After Reallocation
D. Arbitration
1. Background — U.K. Treaties
2. Arbitration Procedures Under Other U.K. International Agreements
3. Need for Arbitration
E. Protecting the Availability of U.K. Foreign Tax Credits
F. Application to U.K. Dependencies
175:IV. Advance Pricing Agreements
175:V. Consultation Between Competent Authorities Regarding Treaty Interpretation or Application
A. In General
B. Scope of Consultation Provisions
C. Use of Consultation Procedure
D. Legal Effect of Consultations
175:VI. Exchange of Information
A. In General
1. Exchange of Information Outside of International Agreements
2. Exchange of Information Under International Agreements
B. Exchange of Information Under Income Tax Treaties
1. Scope of Treaty Provisions
a. Taxpayers Covered
b. Taxes Covered
c. Nature of Information
2. Types of Exchanges
a. In General
b. Exchanges Regarding Changes in Tax Laws
c. Automatic Exchange of Information
d. Spontaneous Exchange of Information
e. Specific Requests for Information
f. Industry-Wide and Issue-Specific Exchange of Information
3. Simultaneous Examination Programs
a. General Purpose
b. Specific Objectives
c. Procedures
d. Disclosure of Information
4. Responding to Specific Information Requests Under Tax Treaties
a. Specificity of Request
b. Use of Revenue Powers to Obtain Information
c. Mutuality Clause
5. Business Secrets
6. Restrictions on Use and Disclosure of Exchanged Information
a. Use for Tax Purposes Only
b. Restrictions on Disclosure
c. Nondisclosure to Parliament
d. Nondisclosure to Third Countries
C. Exchange of Information Under Tax Information Exchange Agreements
D. Exchange of Information Under Other International Agreements
1. Arbitration Convention
2. EU Administrative Cooperation Directive
a. Automatic Exchange of Information
b. Exchange of Information upon Request
c. Spontaneous Exchange of Information
3. Intergovernmental Agreements to Improve Tax Compliance
a. FATCA IGA
b. Other Agreements
E. Exchange of Information under the FATCA IGA Concluded with the United States
1. Introduction
2. Implementation of the FATCA IGA in the United Kingdom
F. Exchange of Information under the CRS
1. Introduction
2. Implementation of the CRS in the United Kingdom
175:VII. Assistance in Tax Collection

Working Papers

Table of Worksheets
Worksheet 1 Information on Mutual Agreement Procedure from the official website of the Ministry of Finance
Worksheet 2 Article 24 of the Model Income Tax Treaty
Worksheet 3 Article 24 of the Convention between the United States of America and the Russian Federation for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital
Worksheet 4 Article 26 of the Agreement between the Government of the Russian Federation and the Government of the Kingdom of the Netherlands for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on property
Worksheet 5 Article 25 Convention between the Government of the Portuguese Republic and the government of the Russian Federation for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income
Worksheet 6 Article 25 Convention between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the Russian Federation for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income
Worksheet 21 MAP Chart
Worksheet 22 EOI Mechanisms
Worksheet 23 TIEAs: Response Times
Worksheet 24 TIEAs Signed by Spain as of 12/31/11
Worksheet 25 Income Tax Treaties Signed by Spain as of 12/31/12 that Include a Clause on Assistance in Tax Collection
Worksheet 31 Swedish Competent Authority Resources
Worksheet 41 1996 U.S.-Switzerland Income Tax Treaty, art. 26
Worksheet 42 1996 Protocol to the U.S.-Switzerland Income Tax Treaty, ¶10
Worksheet 43 1996 Memorandum of Understanding to the U.S.-Switzerland Income Tax Treaty, ¶8
Worksheet 44 UBS Agreement
Worksheet 45 2009 Protocol to the U.S.-Switzerland Income Tax Treaty, arts. 3 and 4 and Exchange of Notes
Worksheet 46 Selected Swiss Statutes and Federal Tax Administration (FTA) Guidance
Worksheet 47 Agreement Between the United States of America and Switzerland for Cooperation to Facilitate the Implementation of FATCA
Worksheet 51 U.K. Mutual Agreement Procedures and Arbitration Procedures (HMRC Statement of Practice SP 1/11)