On 13 January 2020, final regulations to implement EU Directive 2018/822 (also known as DAC6) on the mandatory disclosure and exchange of cross-border arrangements were laid before Parliament. They are expected to become law within a few weeks.
The final regulations incorporate a number of changes made following consultation on the draft regulations which were published last year. HMRC has also published a summary of responses to that consultation, and following further consultation it will publish final guidance before the regulations come into force in July 2020.
If the UK leaves the EU on 31 January 2020 as expected, under the transitional arrangement provided for in the Withdrawal Agreement these rules will continue to apply at least until the future economic partnership between the UK and the EU is determined.
