The UK joins other jurisdictions in delaying by six months the reporting deadlines for the new mandatory disclosure rules under DAC 6 which come into force on 1 July (although they apply retrospectively from 25 June 2018). HMRC confirms that, exceptionally, claims for carry back loss relief can be made on the basis of anticipated losses if adequate evidence is provided. The OECD continues to facilitate work on the reform of the international tax rules even though an agreement including the US on pillar one will not now be possible until after the US election. US Treasury guidance provides that from 1 July when the USMCA replaced the NAFTA, any reference to the NAFTA in a US tax treaty should be interpreted as a reference to the USMCA, but there is no such helpful guidance extending the meaning of ‘equivalent beneficiary’ under US treaties to include UK residents.
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The UK joins other jurisdictions in delaying by six months the reporting deadlines for the new mandatory disclosure rules under DAC 6 which come into force on 1 July (although they apply retrospectively from 25 June 2018). HMRC confirms that, exceptionally, claims for carry back loss relief can be made on the basis of anticipated losses if adequate evidence is provided. The OECD continues to facilitate work on the reform of the international tax rules even though an agreement including the US on pillar one will not now be possible until after the US election. US Treasury guidance provides that from 1 July when the USMCA replaced the NAFTA, any reference to the NAFTA in a US tax treaty should be interpreted as a reference to the USMCA, but there is no such helpful guidance extending the meaning of ‘equivalent beneficiary’ under US treaties to include UK residents.
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