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the regulations and a document summarizing responses received in the consultation process, HMRC also has circulated draft guidance within HMRC’s DAC6 stakeholder working group for comments.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.
