DAC6 Advisory: UK Mandatory Disclosure Regime

FTI Consulting European Tax Advisory

Corporate Finance & Restructuring

July 1, 2020

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From 1 January 2021 companies and advisors will have to make reports to HMRC in accordance with the International Tax Enforcement (Disclosable Arrangements) Regulations 2020 which implements EU Directive 2018/822, more commonly known as DAC6. This obligation covers cross-border arrangements that began on or after 25 June 2018.

In this service sheet we outline the DAC6 requirements, and how FTI Consulting are able to provide advisory services to organisations who are dealing with their DAC6 obligations in-house, covering impact analysis, process design, training, support and HMRC filing.

Background to DAC6

DAC6 covers the reporting of cross-border arrangements that bear one or more of the hallmarks that may be associated with abusive tax behaviour, but which can also relate to entirely commercial arrangements.

Any organisation that is involved in cross-border activities therefore needs to check whether any of these might be reportable under this regulation. The hallmarks to look out for include areas as common and diverse as confidentiality, fees contingent on tax savings, intra-group deductions and transfers of intangible assets.

Assessment of Relevant Activities and DAC6 Impact

For those organisations that have not encountered DAC6 before, or have not realised that it could apply to them, it will be important to start with an impact analysis.

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