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DAC 6: six types of ambiguity

Dominic Lawrance and Elinor Boote (Charles Russell Speechlys) discuss the uncertainty of the reporting requirements and the potentially serious regulatory burdens for tax professionals dealing with international matters.

EU Council Directive 2018/822 (‘DAC 6’) was passed in May 2018 and has been incorporated into UK law by the International Tax Enforcement (Disclosable Arrangements) Regulations SI 2020/25 (‘the regulations’). Together these instruments have introduced a mandatory reporting regime which requires ‘UK intermediaries’ to report details of certain cross-border arrangements to HMRC. The regime is intended to expose ‘aggressive tax avoidance’ within the EU.

Unless there is a coronavirus-related postponement (which is possible as a proposal to postpone has been tabled by the European Commission) the regulations will take effect from 1 July 2020 and will apply retrospectively to certain reportable cross-border arrangements dating back to 25 June 2018. Generally ...

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