Corporation Tax

DAC 6 ― reporting of cross-border tax arrangements

Produced by Tolley
  • 08 Dec 2021 14:11

The following Corporation Tax guidance note Produced by Tolley provides comprehensive and up to date tax information covering:

  • DAC 6 ― reporting of cross-border tax arrangements
  • Background to DAC 6 and post-Brexit changes
  • Who must make a DAC 6 report?
  • Intermediaries
  • Intermediaries and legal professional privilege
  • Relevant taxpayers
  • What type of arrangements are reportable?
  • What are the category D hallmarks?
  • DAC 6 reporting deadlines
  • Timing of reports triggered before 1 January 2021
  • More...

DAC 6 ― reporting of cross-border tax arrangements

Background to DAC 6 and post-Brexit changes

DAC 6 is an EU Directive which obliges intermediaries, and in some cases taxpayers, to report information to tax authorities about cross-border arrangements which contain certain characteristics, or ‘hallmarks’. In this context, cross-border involves more than one member state or a member state and a third (non-EU) country. The rules are designed to provide tax authorities with more information about direct tax planning arrangements (rather than those involving indirect taxes and duties), although arrangements that do not have a tax avoidance motive may also be caught.

The UK ceased to be an EU member state on 31 January 2020. The implementation period (IP), during which the UK continued to be treated as a member state for many purposes, ended on 31 December 2020 (IP completion day). The UK was obliged to implement DAC 6 into domestic legislation during this time, and did so in the form of the ‘disclosable arrangements’ rules, which came into force on 1 July 2020. The first reporting deadline is 30 January 2021.

However, with effect from IP completion day, and therefore before any UK reports had to be made, the UK Government significantly restricted the scope of the disclosable arrangements rules. As a result, the only arrangements that now need to be reported in the UK under DAC 6 are those that relate to the avoidance of obligations to report information on financial accounts, or that obscure beneficial ownership (hallmark category

Access this article and thousands of others like it
free for 7 days with a trial of TolleyGuidance.

Think Tax.
Think Tolley.

Critical, comprehensive and up-to-date tax information

LEARN MORE LEARN MORE

Popular Articles

Taxation of dividend income

IntroductionA dividend is a distribution of profit by a company to its shareholders.A dividend is not only a payment in cash. It can be the issue of new shares in exchange for forfeiting the right to a cash payment (a stock dividend). For more detail, see the Cash dividends and Non-cash dividends

09 Nov 2021 11:31 | Produced by Tolley Read more Read more

Partial exemption de minimis limit

This guidance note provides an overview of the partial exemption de minimis rules. This note should be read in conjunction with the Partial exemption overview guidance note. If a business incurs an insignificant amount of input tax which is associated with exempt supplies (exempt input tax), it may

19 Oct 2021 22:57 | Produced by Tolley Read more Read more

Indexation allowance and rebasing

This guidance note explains the general rules surrounding the availability of indexation allowance on the disposal of company assets and provides information on the rebasing rules for assets held on 31 March 1982. For an overview of the general position regarding company disposals, please refer to

19 Oct 2021 22:59 | Produced by Tolley in association with Jackie Barker of Wells Associates Read more Read more