349 International arrangements for exchanging information

Other

349  International arrangements for exchanging information

(1)     The Treasury may make regulations for, or in connection with, giving effect to international tax compliance arrangements to any extent, subject to such exceptions or modifications as the Treasury consider appropriate.

(2)     For the purposes of this section, “international tax compliance arrangements” means any provision of—

(a)     arrangements specified in an Order in Council made under section 173 of FA 2006 (international tax enforcement arrangements);

(b)     the agreement reached between the Government of the United Kingdom and the Government of the United States of America to improve international tax compliance and to implement the provisions commonly known as the Foreign Account Tax Compliance Act in the enactment of the United States of America called the Hiring Incentives to Restore Employment Act, signed on 12 September 2012;

(c)     the guidance on country-by-country reporting contained in the Organisation for Economic Co-operation and Development (“OECD”) Guidance on Transfer Pricing Documentation and Country-by-Country Reporting, published in 2014;

(d)     the OECD Standard for Automatic Exchange of Financial Account Information in Tax Matters, published in 2014;

(e)     the OECD Model Mandatory Disclosure Rules for CRS Avoidance Arrangements and Opaque Offshore Structures, published

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