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DAC 6: Brexit reprieve

23 February 2021 / Jason Collins , Hatice Ismail
Issue: 4781 / Categories: Comment & Analysis
DAC 6: Brexit reprieve

Key points

  • As an unexpected result of Brexit the UK has introduced only a limited DAC 6 regime for reporting cross-border arrangements.
  • Reporting required in the UK only for hallmark D arrangements – those which undermine the common reporting system or obscure beneficial ownership.
  • UK advisers with EU offices may need to report other arrangements in the EU and there may be double reporting of hallmark D arrangements.
  • Unclear how tax authorities will exchange information on arrangements disclosed.
  • HMRC will consult on replacement rules this year.

The end of 2020 brought a reprieve for UK advisers – it became clear that the UK was no longer going ahead with the full-blown reporting system required by DAC 6 which from 31 January would have required advisers (and others) to report to HMRC cross-border arrangements involving a range of prescribed hallmarks categorised A to E. The UK rules now only require the...

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