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The UK DAC 6 regulations: the good, the bad and the unknown

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The UK regulations implementing the EU’s ‘DAC 6’ directive have now been laid before Parliament. Tax professionals had been eagerly awaiting clarification on key issues as they try to determine which transactions could be in scope and implement internal processes for capturing and reporting relevant arrangements. Whilst the final regulations provide some of the answers, there are still significant areas of uncertainty and the HMRC guidance is not expected to be published until June. As a result, getting procedures in place in time for the first reports in August is going to be a challenge.
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