The draft UK regulations follow DAC6 closely, and require disclosure to HMRC of cross border arrangements entered into by taxpayers which fall within certain hallmarks . These hallmarks are very broadly defined and many commercial transactions will be within the scope of the rules . The disclosures will be shared between the tax authorities of all EU Member States quarterly.
The consultation document sets out the approach HMRC intends to take in interpreting DAC6 and elaborates on how the rules will operate in practice. HMRC will provide further guidance alongside the finalised regulations.
The regulations enter into force on 1 July 2020 , but transitional rules mean that they can apply to transactions happening now.
View the download below for more details.