The UK government is to defer the first reporting deadlines under the International Tax Enforcement (Disclosable Arrangements) Regulations, SI 2020/25, by six months, as confirmed by HMRC in an update to its International Exchange of Information Manual (at IEIM800010). The manual sets out the relevant revised deadlines and notes that, although amendments to the regulations may not be in force by 1 July 2020, ‘no action will be taken for non-reporting during the period between 1 July and the date the amended regulations come into force’.
Dan Neidle, tax partner at Clifford Chance, said the deferral ‘will be broadly welcomed, given the complexity and practical difficulty of implementing DAC 6 for large businesses (and indeed for advisers).’
The UK changes follow European Council approval of amendments to the Directive on Administrative Cooperation (DAC: Directive 2011/16/EU) giving member states the option to defer by up to six months the time limits for the filing and exchange of the following information:
automatic exchanges of information on financial accounts of which the beneficiaries are tax residents in another member state; and
The amendments are made by Council Directive 2020/876/EU of 24 June 2020 ‘to address the urgent need to defer certain time limits for the filing and exchange of information in the field of taxation because of the COVID-19 pandemic’.
The UK government is to defer the first reporting deadlines under the International Tax Enforcement (Disclosable Arrangements) Regulations, SI 2020/25, by six months, as confirmed by HMRC in an update to its International Exchange of Information Manual (at IEIM800010). The manual sets out the relevant revised deadlines and notes that, although amendments to the regulations may not be in force by 1 July 2020, ‘no action will be taken for non-reporting during the period between 1 July and the date the amended regulations come into force’.
Dan Neidle, tax partner at Clifford Chance, said the deferral ‘will be broadly welcomed, given the complexity and practical difficulty of implementing DAC 6 for large businesses (and indeed for advisers).’
The UK changes follow European Council approval of amendments to the Directive on Administrative Cooperation (DAC: Directive 2011/16/EU) giving member states the option to defer by up to six months the time limits for the filing and exchange of the following information:
automatic exchanges of information on financial accounts of which the beneficiaries are tax residents in another member state; and
The amendments are made by Council Directive 2020/876/EU of 24 June 2020 ‘to address the urgent need to defer certain time limits for the filing and exchange of information in the field of taxation because of the COVID-19 pandemic’.
