The following Tax guidance note provides comprehensive and up to date legal information covering:
The UK’s disclosable arrangements rules implement EU Directive 2018/822, also known as DAC 6, or the EU Mandatory Disclosure Regime (EU MDR). The rules oblige ‘intermediaries’ (as defined), and in some cases taxpayers, to report information to HMRC about cross-border arrangements that contain certain hallmarks. Cross-border means concerning more than one EU Member State, or a Member State and a third (non-EU) country. The hallmarks are designed to catch tax-planning arrangements, but arrangements without a tax avoidance motive may also be caught.
DAC 6 followed on from the Organisation for Economic Cooperation and Development’s (OECD’s) Base Erosion and Profit Shifting (BEPS) Project, Action 12, on the disclosure of aggressive tax planning, although DAC 6 also applies to arrangements that would not ordinarily be regarded as aggressive tax planning.
DAC 6 amended Directive 2011/16/EU, the Directive for Administrative Cooperation (DAC). This is the fifth Directive amending the DAC and is therefore referred to (counting the original DAC plus the five amending Directives) as DAC 6. For information on the DAC, see Practice Note: Directive for administrative cooperation in the field of taxation (DAC)—FAQs.
This Practice Note is about DAC 6 as implemented in the UK. All EU Member States were required to implement DAC 6, but this is a minimum standard and there are some significant differences between different countries’ rules, for example in the
**Trials are provided to all LexisPSL and LexisLibrary content, excluding Practice Compliance, Practice Management and Risk and Compliance, subscription packages are tailored to your specific needs. To discuss trialling these LexisPSL services please email customer service via our online form. Free trials are only available to individuals based in the UK. We may terminate this trial at any time or decide not to give a trial, for any reason. Trial includes one question to LexisAsk during the length of the trial.
To view the latest version of this document and thousands of others like it, sign-in to LexisPSL or register for a free trial.
Existing user? Sign-in
Take a free trial
0330 161 1234
To view our latest legal guidance content,sign-in to Lexis®PSL or register for a free trial.