JONES DAY PRESENTS®: EU Mandatory Disclosure Rules (DAC 6)
The UK Government has published the final version of regulations on 17 January 2023 that will give effect to the UK’s mandatory disclosure rules (“UK MDR”). The International Tax Enforcement (Disclosable Arrangements)...more
IP rights with a nexus to Germany can create a variety of tax issues under German tax law. These include aspects of German or foreign IP rights generating “German source income,” questions of withholding tax obligations, a...more
On the eve of the UK's exit from the EU on 31 December 2020, the UK Government published the concise but game-changing piece of legislation, 'The International Tax Enforcement (Disclosable Arrangements) (Amendment) (No. 2)...more
The UK has made important changes to its implementation of the EU Mandatory Tax Disclosure Rules known as DAC6. The changes, which significantly reduce the scope of the rules in the UK ...more
On 31 December 2020, HMRC unexpectedly announced that the UK will repeal the implementation of the EU Directive on administrative cooperation (“DAC6”).Instead, the UK will introduce its own mandatory disclosure rules (“MDR”)...more
The UK has made important changes to its implementation of the EU Mandatory Tax Disclosure Rules known as DAC6. The changes, which significantly reduce the scope of the rules in the UK, are largely good news for UK taxpayers...more
Despite much anticipation to the contrary, the UK Government decided to repeal all but one of the reporting triggers under the UK regulations implementing EU Council Directive 2018/822 on the reporting of cross-border tax...more
In light of Brexit, the U.K. government has made the unexpected announcement that it will limit DAC6 (Directive 2018/822) reporting in the U.K. to matters involving arrangements with the effect of concealing the ultimate...more
Following the agreement of the EU/UK Trade and Cooperation Agreement (the “Brexit Deal”), HMRC has unexpectedly announced a substantial restriction to the way in which DAC6 will be applied in the UK. Although the law has...more
Coinciding with the end of the UK-EU Brexit transition period, the United Kingdom has dramatically reduced the scope of DAC 6 reporting obligations in the United Kingdom. ...more
Our International Tax Transparency Update will cover DAC6, the UK’s Trust Registration Service and other global registration requirements that may be relevant for businesses. The importance of these requirements cannot be...more
Two Birds, One Stone: Addressing COO and DAC6 Risks in Tandem - UK Criminal Finances Act 2017 (CFA) and the EU Directive on Administrative Cooperation (DAC6) compliance matters are likely to come under increased scrutiny...more
Sarah Gabbai, Nicholas Holland, Lynsey McIntyre and Ziva Robertson will discuss recent vital regulatory and jurisprudential developments for international fiduciaries. The panel will discuss: - Reporting obligations...more
DAC6, the European Union's new disclosure regime, imposes the reporting of cross-border tax arrangements for multinational enterprises in 28 European countries. Jones Day partners Florian Lechner (Frankfurt) and Carlos...more
On 24 June, the Council of the European Union formally adopted a directive giving EU Member States the option to defer by six months the timetable for reporting under DAC6. ...more
DAC 6 is a new regime under which intermediaries and/or taxpayers must report to an EU tax authority information about cross-border arrangements with a view to the information being exchanged with other EU tax authorities. ...more
HM Revenue & Customs confirmed on June 25, 2020, that the United Kingdom will adopt a European Union measure to delay the first reporting requirement under EU Council Directive 2018/822, the sixth amendment to the EU...more
Political Agreement - Following the recent European Commission proposal to postpone the initial reporting deadlines for “DAC6” by three months, EU Commission proposes extension of the DAC6 reporting deadlines, a political...more
In our latest interactive webinar we will discuss DAC6 – the EU Directive on reportable cross-border tax arrangements – and its impact on business. The importance of DAC6 cannot be overstated. As an intermediary,...more
DAC6 summary - Council Directive 2018/822 – known as DAC6 – is the sixth amendment to the EU Directive on Administrative Cooperation 2011/16/EU. DAC6 is aimed at providing the tax authorities with a “warning system” in...more