On 22 July 2019, HMRC published a consultation document on the implementation of Council Directive 2018/822 EU (amending Directive 2011/16/EU), known as DAC 6. The document contains draft regulations that largely replicate or cross refer to the Directive, but the consultation also provides some insight into HMRC’s likely approach to implementation. In a number of areas HMRC’s position is helpful, limiting the potential extent of disclosure in the UK. However, the possibility of a lack of alignment of domestic regimes across the EU means that taxpayers may need to consider rules across a number of jurisdictions even where the UK guidance indicates that a transaction is not disclosable.
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On 22 July 2019, HMRC published a consultation document on the implementation of Council Directive 2018/822 EU (amending Directive 2011/16/EU), known as DAC 6. The document contains draft regulations that largely replicate or cross refer to the Directive, but the consultation also provides some insight into HMRC’s likely approach to implementation. In a number of areas HMRC’s position is helpful, limiting the potential extent of disclosure in the UK. However, the possibility of a lack of alignment of domestic regimes across the EU means that taxpayers may need to consider rules across a number of jurisdictions even where the UK guidance indicates that a transaction is not disclosable.
If you are not a subscriber, subscribe now to read this content.
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