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International review for February 2020

Tim Sarson (KPMG) assesses the latest developments that matter in the international tax arena.

UK’s final DAC 6 regulations

Whilst last month’s update (Tax Journal 31 January 2020) mentioned that the regulations to transpose DAC 6 into UK law have now been presented before Parliament (SI 2020/25) it is worth looking into how the latest updates have shaped the regulations especially as the first reporting deadline is fast approaching.

The territorial scope of the rules has been narrowed by the introduction of new definitions for ‘UK intermediaries’ and ‘UK relevant taxpayers’. The aim is to ensure that the rules do not apply to intermediaries without a connection to the UK which is in line with the intention of DAC 6.

Whilst HMRC acknowledges that some duplicate reporting of arrangements is inevitable the final regulations ensure that the same intermediary does not have...

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