Readers are reminded that the UK’s new mandatory disclosure rules take effect from 28 March 2023 and will require arrangements caught by the rules and entered into on or after this date to be reported to HMRC. HMRC has now published a new guidance page and a schema and supporting documents.
Overall, the new rules are intended to implement the OECD 2018 Model Mandatory Disclosure Rules for Common Reporting Standard avoidance arrangements and opaque offshore structures. They impose obligations on persons, known as intermediaries or reportable taxpayers, to report information to HMRC about these types of arrangements.