UK repeals most of DAC6 reporting triggers

The government has repealed all but one of the reporting hallmarks under the UK regulations implementing EU Council Directive 2018/822 on the reporting of cross-border tax arrangements (DAC6). The International Tax Enforcement (Disclosable Arrangements) (Amendment) (No 2) (EU Exit) Regulations 2020 leave only hallmark category D which applies to cross-border arrangements that circumvent the requirements of the common reporting standard and that involve non-transparent structures that make the beneficial owners unidentifiable.  

Gary Ashford tax partner at Harbottle & Lewis said: ‘This a sign of more changes to come post-Brexit. The government is wasting no time in demonstrating it will take its own path in terms of its international tax compliance obligations.  

‘HMRC is making it clear it will still implement some parts in relation to those who sought to circumvent common reporting standard reporting and will also consult on further changes. If the non-UK side of...