Overview of the DAC 6 disclosable arrangements regime
Owner-Managed Businesses
Guidance
The rules described below applied in the UK until their repeal on 28 March 2023. After this date, details of offshore avoidance arrangements must be reported under the mandatory disclosure rules (MDR), which are explained in the Mandatory disclosure rules (MDR) ― overview guidance note.
What is DAC 6?
DAC 6 is the name given to an EU Directive that requires member states to enact rules designed to provide tax authorities with more information about direct tax planning arrangements.
Intermediaries, and in some cases taxpayers, must report information about cross-border arrangements that contain certain characteristics, or ‘hallmarks’. For this purpose, the term ‘cross-border’ involves more than one member state, or a member state and a third (non-EU) country. The overall aim is to provide tax authorities with more information about direct tax planning arrangements, although some of the hallmarks are widely drafted such that certain arrangements without a tax avoidance motive may also be caught.
Implementing DAC 6 in the UK
The UK regulations that implemented the provisions of the Directive (sometimes
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