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The UK DAC 6 regulations: the good, the bad and the unknown

Brin Rajathurai (Freshfields Bruckhaus Deringer) explores the impact of the regulations and some of the key areas where we are still waiting for answers.

The International Tax Enforcement (Disclosable Arrangements) Regulations SI 2020/25 (‘the UK regulations’) were laid before Parliament on 13 January 2020 and take effect from 1 July 2020. These implement EU Directive 2018/822 (DAC 6 referred to herein as ‘the Directive’) which amends the Directive on Administrative Cooperation in the field of taxation (EU Directive 2011/16/EU).

By way of background for those lucky enough not to have had to grapple with DAC 6 so far the Directive requires ‘intermediaries’ and in some cases taxpayers to report arrangements bearing certain characteristics (or ‘hallmarks’) to tax authorities. Member states were required to implement DAC 6 by 31 December 2019. The UK still being a member of the EU...

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