(also known as)
• Directive on administrative cooperation
• Disclosable cross-border tax arrangements
• UK DAC 6 reporting
DAC 6 is the term commonly used to refer to EU Directive 2018/822/EU, which requires member states to enact local laws to gather information on certain cross-border transactions.
UK DAC6 obligations and recent changes in a nutshell
Prior to IP completion day (31 December 2020), intermediaries, and in some cases taxpayers, were obliged to report information to HMRC about cross-border arrangements which contained certain hallmarks. The rules were designed to provide tax authorities with more information about direct tax planning arrangements, sometimes with wide-reaching effect.
However, The International Tax Enforcement (Disclosable Arrangements) (Amendment) (No 2) (EU Exit) Regulations 2020, SI 2020/1649, which took effect on IP completion day, significantly reduced the scope of the arrangements that need to be reported in the UK under DAC 6. Almost all the hallmarks have been removed, other than those in category D which deals with automatic exchange of