The first reporting deadlines under the UK implementation of the EU mandatory disclosure rules (DAC 6) will be deferred by six months.
HMRC have announced that the first reporting deadlines under the UK implementation of the EU mandatory disclosure rules (DAC 6), which come into force on 1 July 2020, will be deferred by six months in order to provide taxpayers and intermediaries dealing with the impacts of COVID-19 additional time to ensure they can comply with their obligations. This article sets out the revised reporting deadlines and key points to note.
The reporting dates will be deferred as follows:
The UK Government will amend the International Tax Enforcement (Disclosable Arrangements) Regulations 2020 to give effect to this deferral and HMRC have advised that, as the amendment may not be in force by 1 July 2020, no action will be taken for non-reporting during any period between 1 July and the date that the amended Regulations come into force. There is therefore no expectation that reports will be made in July 2020.
HMRC have advised that, in light of this deferral, they will not switch on the IT system that will be used for reporting on 1 July 2020, but that the system will be made available ahead of the new deadlines. HMRC will use the additional time to work with taxpayers and intermediaries to ensure the system is ready.
Details of the deferral have been published in HMRC’s International Exchange of Information Manual.
HMRC have suggested that they intend to publish guidance shortly to help businesses in their preparations to meet their reporting obligations.
Key points to note
Despite the six-month deferral, please note the following key points:
Announcements in other Member States
An alert from KPMG’s EU Tax Centre provides details of the Member States that have made announcements thus far. In summary, official announcements have now been made in the following territories:
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