As mentioned above, the UK will not implement DAC6 and therefore, UK entities have no DAC6 reporting obligations in the UK (with the exception regarding the hallmarks D). However, specifically, the following categories of arrangements remain reportable:
- Arrangements between UK and EU group entities. Such arrangements are reportable in the country of residence of the involved EU entity.
- Cross-border arrangements involving a UK intermediary and an EU taxpayer. As the UK intermediary no longer has any reporting obligations, the reporting obligation falls to the EU taxpayer.