Summer 2020 saw the publication of HMRC’s final guidance on the application of DAC 6. Taxpayers and advisers will find much that is welcome in the tone and approach of that guidance. They may, however, be forgiven for having hoped for greater detail and for examples that could more easily be applied to novel situations. If HMRC’s aim was to forestall taxpayer enquiries ahead of the start of reporting in early 2021, then they may find that they have met with only limited success. Taxpayers will also need to bear in mind that, however helpful HMRC’s views may be, they are no guarantee that other member states will take the same approach.
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Summer 2020 saw the publication of HMRC’s final guidance on the application of DAC 6. Taxpayers and advisers will find much that is welcome in the tone and approach of that guidance. They may, however, be forgiven for having hoped for greater detail and for examples that could more easily be applied to novel situations. If HMRC’s aim was to forestall taxpayer enquiries ahead of the start of reporting in early 2021, then they may find that they have met with only limited success. Taxpayers will also need to bear in mind that, however helpful HMRC’s views may be, they are no guarantee that other member states will take the same approach.
If you are not a subscriber, subscribe now to read this content.
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