Chapter IEIM220500

CourtHM Revenue & Customs
Published date25 April 2016
Record NumberIEIM220500

The UK’s Crown Dependencies (the Isle of Man, Guernsey, and Jersey) and Overseas Territories (for example the British Virgin Isles, the Cayman Isles, and Gibraltar) are part of the sovereign state of the United Kingdom. Hence, under international law principles, there cannot be an international agreement between the metropolitan UK and these jurisdictions, or between the jurisdictions themselves, because a state cannot treat with itself.

The Crown Dependencies and most of the Overseas Territories have their own tax or finance authorities; HMRC cannot directly access information held by these agencies, and nor do they have automatic access to our information. Instead, the UK will make ‘arrangements’ to exchange information. These will normally be in the form of Double Taxation Arrangements or Tax...

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