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At Budget 2018, the government announced that it would introduce legislation to implement EU Directive 2018/22 - known as the EU Mandatory Disclosure Regime (EU MDR) or DAC 6 - requiring taxpayers and their advisers to disclose details of certain cross-border arrangements to HMRC.

The government consulted on draft legislation over summer 2019 and has now laid final Regulations before Parliament (as well as releasing their responses to the consultation and an impact assessment).  These Regulations will become law unless the House of Commons passes a motion preventing that before 3 March, which is extremely unlikely.  They are due to come into force on 1 July 2020.

Consultation outcome

HMRC Policy paper: International Tax Enforcement: disclosable cross-border arrangements