Last month, HMRC published the outcome of the consultation seeking views on the requiring disclosure of certain arrangements to HMRC. At the same time draft regulations have been published which seek to implement the OECD mandatory disclosure rules, sometimes known as DAC6, for common reporting standard (“CRS”) avoidance arrangements. The rules come into effect from 25 June 2018 rather than the original 2014 start date.
As an EU member state at the time, the UK implemented DAC 6 in January 2020. Now that the UK has left the EU and the transition period has ended, the Government will implement the OECD model rules to replace the EU version of the rules.
According to the draft regulations, the reporting requirement will only be necessary where the value of the financial account that is subject to the CRS avoidance arrangement immediately prior to the implementation of the arrangement was more than $1,000,000 (or sterling equivalent).