The draft provisions contain a number of measures related to enforcement and HMRC powers. Jason Collins (Pinsent Masons) takes a look.
Mandatory disclosure rules
Clause 40 of the draft bill contains a power to enable the making of regulations to transpose into UK law the disclosure regimes under the EU’s directive on administrative cooperation 2018/822 (DAC 6) and the OECD’s ‘model’ mandatory disclosure rules (MMDR).
Both regimes require qualifying intermediaries to report details of certain arrangements relating to the avoidance of common reporting standard (CRS) and automatic exchange of information (AEOI) reporting (albeit with subtle but important differences). However DAC 6 also requires reporting in respect of arrangements where cross-border tax arbitrage may be involved.
The power allows the regulations to amend primary legislation. The HMRC policy paper notes that the UK’s disclosure of tax avoidance schemes (DOTAS) overlaps to an extent with these new disclosure regimes...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
The draft provisions contain a number of measures related to enforcement and HMRC powers. Jason Collins (Pinsent Masons) takes a look.
Mandatory disclosure rules
Clause 40 of the draft bill contains a power to enable the making of regulations to transpose into UK law the disclosure regimes under the EU’s directive on administrative cooperation 2018/822 (DAC 6) and the OECD’s ‘model’ mandatory disclosure rules (MMDR).
Both regimes require qualifying intermediaries to report details of certain arrangements relating to the avoidance of common reporting standard (CRS) and automatic exchange of information (AEOI) reporting (albeit with subtle but important differences). However DAC 6 also requires reporting in respect of arrangements where cross-border tax arbitrage may be involved.
The power allows the regulations to amend primary legislation. The HMRC policy paper notes that the UK’s disclosure of tax avoidance schemes (DOTAS) overlaps to an extent with these new disclosure regimes...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
