DAC 6 ― reporting of cross-border tax arrangements

Produced by a Tolley Corporation Tax expert

Corporation Tax

Guidance

The rules described below apply 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.

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

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