Matthew Hodkin and Susie Brain (Norton Rose Fulbright) consider HMRC's proposed approach to implementation and how reporting is likely to work within the context of the UK tax system.
Legislative history and timetable
DAC 6 came into force on 25 June 2018 and provided a timetable for EU member states to implement the disclosure regime which forms part of the wider EU regime on automatic exchange of information. Member states are required to introduce implementing legislation by 31 December 2019 and the first disclosures are to be made after 1 July 2020.
This has created an immediate problem in that DAC 6 will ultimately require taxpayers to make disclosures in relation to transactions entered into on or after 25 June 2018 even though domestic implementing legislation has only now begun to emerge. This means that taxpayers (and advisers) may now face...
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Matthew Hodkin and Susie Brain (Norton Rose Fulbright) consider HMRC's proposed approach to implementation and how reporting is likely to work within the context of the UK tax system.
Legislative history and timetable
DAC 6 came into force on 25 June 2018 and provided a timetable for EU member states to implement the disclosure regime which forms part of the wider EU regime on automatic exchange of information. Member states are required to introduce implementing legislation by 31 December 2019 and the first disclosures are to be made after 1 July 2020.
This has created an immediate problem in that DAC 6 will ultimately require taxpayers to make disclosures in relation to transactions entered into on or after 25 June 2018 even though domestic implementing legislation has only now begun to emerge. This means that taxpayers (and advisers) may now face...
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:
