DAC 6: Brexit reprieve

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 reporting of arrangements falling under hallmark D namely those which – in broad terms – undermine the common reporting standard or disguise beneficial ownership.

What is DAC 6?

DAC 6 is so named because it is the sixth version of the heavily-amended EU Directive of Administrative Co-operation (DAC) (Directive 2011/16). The DAC series covers a range of policy areas in tax where member states must co-operate with each other. DAC 6 required member states to legislate to require ‘intermediaries’ with a relevant EU nexus to...