Many aspects of DAC 6 are ambiguous and have the potential to impose serious regulatory burdens on tax professionals working on matters where there is an international dimension. At the time of writing, there is debate about whether reporting will, in practice, be required of lawyers, given that legal advice is normally privileged. Another area of uncertainty is the meaning of ‘tax advantage’ and how this fit in with the purposive approach that is increasingly being taken by the UK tax courts. In addition, many of the DAC 6 hallmarks are difficult to construe.
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Many aspects of DAC 6 are ambiguous and have the potential to impose serious regulatory burdens on tax professionals working on matters where there is an international dimension. At the time of writing, there is debate about whether reporting will, in practice, be required of lawyers, given that legal advice is normally privileged. Another area of uncertainty is the meaning of ‘tax advantage’ and how this fit in with the purposive approach that is increasingly being taken by the UK tax courts. In addition, many of the DAC 6 hallmarks are difficult to construe.
If you are not a subscriber, subscribe now to read this content.
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