Helen Buchanan and John Tolman (Freshfields Bruckhaus Deringer) discuss the published guidance that still leaves many key questions around the scope of DAC 6 reporting obligations.
At the end of June HMRC finally published its long-awaited guidance on the UK implementation of the mandatory disclosure rules contained in the Directive on Administrative Cooperation (2011/16/EU) as amended by Directive 2018/882/EU (DAC 6). Coming as this did only days before live reporting under DAC 6 was originally scheduled to commence taxpayers and advisers can be grateful that (in common with most member states) the UK has taken the decision to defer the implementation of DAC 6 by six months. Generally speaking as we explain below the guidance is helpful and pragmatic in tone but still leaves many unanswered questions and areas where further elaboration would be helpful.
Background
By way of brief recap DAC 6 requires ‘intermediaries’ (a...
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Helen Buchanan and John Tolman (Freshfields Bruckhaus Deringer) discuss the published guidance that still leaves many key questions around the scope of DAC 6 reporting obligations.
At the end of June HMRC finally published its long-awaited guidance on the UK implementation of the mandatory disclosure rules contained in the Directive on Administrative Cooperation (2011/16/EU) as amended by Directive 2018/882/EU (DAC 6). Coming as this did only days before live reporting under DAC 6 was originally scheduled to commence taxpayers and advisers can be grateful that (in common with most member states) the UK has taken the decision to defer the implementation of DAC 6 by six months. Generally speaking as we explain below the guidance is helpful and pragmatic in tone but still leaves many unanswered questions and areas where further elaboration would be helpful.
Background
By way of brief recap DAC 6 requires ‘intermediaries’ (a...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
