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ARCHIVED: This flowchart has been archived and is not maintained.

STOP PRESS: On 28 March 2023 the disclosable arrangements (DAC 6) legislation was replaced by the Mandatory Disclosure Rules (MDR) legislation. The DAC 6 legislation and HMRC guidance has been withdrawn.

As described in Practice Note: Disclosable cross-border tax arrangements—DAC 6 [Archived], the scope of the UK’s disclosable arrangements rules was significantly reduced with effect from IP completion day (11 pm on 31 December 2020). The remaining disclosable arrangements rules were replaced entirely on 28 March 2023 with new legislation specifically to implement the OECD Mandatory Disclosure Rules (MDR) as set out in The International Tax Enforcement (Disclosable Arrangements) Regulations 2023, SI 2023/38 (MDR regulations). Although the DAC 6 regulations, SI 2020/25 have been revoked with effect from 28 March 2023, they still have effect in relation to arrangements entered into before that date. An arrangement entered into immediately prior to 28 March 2023 does not fall between the two regimes — it is still reportable under the DAC 6 rules in SI