Printed from https://fyi.org.nz/request/7224-memorandum-of-understanding-specific-to-article-25a-in-dta-relief-united-kingdom-amendment-order-2008-or-maa-2013 on November 04, 2025 20:43

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Memorandum of Understanding specific to Article 25A in DTA Relief (United Kingdom) Amendment Order 2008, or MAA (2013)

Mr Clifford made this Official Information request to Inland Revenue Department

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From: Mr Clifford

Dear Inland Revenue Department,

Please provide a copy of the current Memorandum of Understanding (MoU) document which specifically handles the functioning of Article 25A in Double Taxation Relief (United Kingdom) Amendment Order 2008, or, if this is superseded, then the MoU applicable (for UK) to Section II of Double Tax Agreements (Mutual Administrative Assistance) Order 2013.

Note, that in Ben Nevis (Holdings) Ltd & Metlica Trading Ltd v HMRC [2013] EWCA Civ 578, the England and Wales Court of Appeal justices wrote in their verdict: [41] “...in the interests of fairness to taxpayers such Memoranda of Understanding should be readily available to the public”.

Yours faithfully,

Mr Clifford

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From: oia
Inland Revenue Department

Attachment 0902181203415846.pdf
29K Download View as HTML

Good afternoon,

 

Please find attached an acknowledgement of your recent Official
Information Act request, sent on behalf of Kerryn McIntosh-Watt, Manager
Government and Executive Services.

 

Government and Executive Services

 

This email and any attachment may contain confidential information. If you
have received this email or any attachment in error, please delete the
email / attachment, and notify the sender. Please do not copy, disclose or
use the email, any attachment, or any information contained in them.
Consider the environment before deciding to print: avoid printing if you
can, or consider printing double-sided. Visit us online at ird.govt.nz

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From: Sarah Letellier
Inland Revenue Department

Attachment UK NZ MOA for OIA 153 Mr Clifford.pdf
3.2M Download View as HTML

Attachment OIA 153 response Mr Clifford.pdf
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Dear Mr Clifford

Please find attached a response to your recent Official Information Act
request, and the document you requested.

 

On behalf of Kerryn McIntosh-Watt

Manager, Government & Executive Services

 

This email and any attachment may contain confidential information. If you
have received this email or any attachment in error, please delete the
email / attachment, and notify the sender. Please do not copy, disclose or
use the email, any attachment, or any information contained in them.
Consider the environment before deciding to print: avoid printing if you
can, or consider printing double-sided. Visit us online at ird.govt.nz

Link to this

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