The following Tax practice 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 formulation of the
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The Financial Conduct Authority Handbook (FCA Handbook) includes sourcebooks to regulate the conduct of business by a regulated firm relevant to insurers: the Conduct of Business Sourcebook (COBS) and the Insurance Conduct of Business Sourcebook (ICOBS). This Practice Note considers how these
The principles of the notarial act are that it is:•an act of the notary and not of the parties named in the document•a record of a fact, event or transaction•in the form of a document, notwithstanding the form of the underlying document, fact, event or transactionThe purpose of the notarial act is
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