Overview of the DAC 6 disclosable arrangements regime

Produced by a Tolley Owner-Managed Businesses expert

Owner-Managed Businesses

Guidance

The rules described below applied in the UK until their repeal on 28 March 2023. After this date, details of offshore avoidance arrangements must be reported under the mandatory disclosure rules (MDR), which are explained in the Mandatory disclosure rules (MDR) ― overview guidance note.

What is DAC 6?

DAC 6 is the name given to an EU Directive that requires member states to enact rules designed to provide tax authorities with more information about direct tax planning arrangements.

Intermediaries, and in some cases taxpayers, must report information about cross-border arrangements that contain certain characteristics, or ‘hallmarks’. For this purpose, the term ‘cross-border’ involves more than one member state, or a member state and a third (non-EU) country. The overall aim is to provide tax authorities with more information about direct tax planning arrangements, although some of the hallmarks are widely drafted such that certain arrangements without a tax avoidance motive may also be caught.

Implementing DAC 6 in the UK

The UK regulations that implemented the provisions of the Directive (sometimes

Access this article and thousands of others like it
free for 7 days with a trial of Tolley+™ Guidance.

TAKE A FREE TRIAL

Popular Articles

Personal Tax

Timing of disposal for capital gains tax

Timing of disposal for capital gains taxDate of disposalThe date of the disposal determines the period in which the gain is subject to capital gains tax (CGT). When the rates of CGT change, the determination of the date of disposal can also affect the rate of CGT that applies to the gain.See the

14 Jul 2020 13:50 | Produced by Tolley Read more

Year-end tax planning

Corporation Tax

Carried-forward losses restriction

Carried-forward losses restrictionOverview of the carried-forward loss restrictionAn important restriction in the use of losses carried forward was introduced by Finance (No 2) Act 2017. Subject to a de minimis of £5m (known as the deductions allowance), most carried-forward losses are restricted to

14 Jul 2020 11:09 | Produced by Tolley Read more

Employment Tax

Income tax paid on behalf of employee

Income tax paid on behalf of employeeIntroductionEmployers may wish to make payments of employment income to an employee / director without the employee suffering a tax or NIC cost on that pay. In other words, the employer wants to pay an amount net of tax and NIC. In some instances, often with

14 Jul 2020 11:58 | Produced by Tolley in association with Paul Tew Read more

��Ӱ��