Changes to DAC6 and OECD Mandatory Tax Reporting
The International Tax Enforcement (Disclosable Arrangements) Regulations 2020 (DAC6) and OECD Mandatory Tax Reporting
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However, as part of the changes brought about by Brexit, significant sections of the regulations have been repealed.
The only disclosure that will now be required in the UK under the Hallmarks is:
Category D – Hallmarks concerning automatic exchange of information and beneficial ownership (which must be interpreted in accordance with the Model Mandatory Disclosure Rules for CRS Avoidance Arrangements and Opaque Offshore Structures approved by the OECD on 8 March 2018).
There is no change to the reporting deadlines and the first report is due by 30 January 2021. HMRC has indicated that its portal for reportable cross-border arrangements will be available from mid-January. No other disclosure is required.
During 2021, the remainder of the regulations will be repealed and that is the end of the good news – because following a period of consultation, new legislation implementing the OECD’s Mandatory Disclosure Rules (MDR) will be introduced.