On 13 January 2020, the final International Tax Enforcement (Disclosable Arrangement) Regulations 2020 that implement the EU mandatory disclosure rules (EU DAC 6 directive) into the United Kingdom (UK) law were published. In addition to publishing the regulations and a document summarizing responses received in the consultation process, HMRC also has circulated draft guidance within HMRCā€™s DAC6 stakeholder working group for comments.

For both taxpayers and intermediaries, where the first step in the implementation of a reportable cross-border arrangement was made between 25 June 2018 and 1 July 2020, the information must be reported between 1 Jul 2020 and 31 August 2020; and where an intermediary or taxpayer is notified of a reporting obligation due to an intermediary claiming legal professional privilege, the information must be reported within 30 days of the notification being received.