IEIM740010 - Who has to report?

As noted at IEIM722020, the primary reporting obligation is on anyone who is an intermediary. The requirement for a reportable taxpayer to report an arrangement to HMRC therefore only applies if there is no intermediary who is required to report the required information in relation to the arrangement. If the reportable taxpayer has evidence that this information has been disclosed by an intermediary to a partner jurisdiction, operating rules that are substantially similar, then this information is not required to be reported.