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The EU reportable arrangement rules for intermediaries

Geoff Hippert (Milestone International Tax Partners) reviews the impact of the new rules.
 

The EU recently introduced a set of reportable tax arrangement rules (‘the EU rules’) inspired by Action 12 of the OECD’s base erosion and profit shifting (BEPS) project on mandatory reporting regimes in an international context.

The EU rules are designed to assist member states in protecting their tax base by increasing the visibility of cross-border tax avoidance schemes and deterring their use.

Like the UK’s disclosure of tax avoidance schemes (DOTAS) and the Irish mandatory reporting scheme for a tax arrangement to be disclosed under the EU rules it must fall within one or more of various ‘hallmarks’.

The UK experience

Most UK tax professionals will agree that the original DOTAS rules were not the panacea the government was seeking in reducing widespread avoidance. The rules are relatively complicated somewhat subjective...

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