In a surprise U-turn, the UK government has narrowed the scope of reporting under DAC 6, such that only cross-border arrangements falling under the category D hallmark will be reportable. The change applies to both historic, and future, arrangements. Nevertheless, reporting under DAC 6 is already required in some EU member states (e.g. Germany), and will shortly be required throughout the EU. Accordingly, arrangements that would otherwise have been reportable to HMRC may now need to be reported to other tax authorities. In the coming year, the UK intends to replace DAC 6 with the OECD’s mandatory disclosure rules.
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In a surprise U-turn, the UK government has narrowed the scope of reporting under DAC 6, such that only cross-border arrangements falling under the category D hallmark will be reportable. The change applies to both historic, and future, arrangements. Nevertheless, reporting under DAC 6 is already required in some EU member states (e.g. Germany), and will shortly be required throughout the EU. Accordingly, arrangements that would otherwise have been reportable to HMRC may now need to be reported to other tax authorities. In the coming year, the UK intends to replace DAC 6 with the OECD’s mandatory disclosure rules.
If you are not a subscriber, subscribe now to read this content.
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