The UK has amended the regulations aligned with EU Directive DAC6. Those involved in cross-border aggressive tax planning arrangements must report these structures to HMRC by 31 January 2021.

Failure to file these arrangements with HMRC may result in penalties of up to £5,000. The types of arrangements that could be caught include:

  • Loan agreements.
  • Payments from a resident of one country to a resident of another.
  • Putting funds in an offshore trust.

A report must be made within 30 days of the earliest of:

  • The day after the arrangement is made available.
  • The day after the arrangement is ready to start.
  • The date the arrangement started.
  • The day after aid, assistance or advice was provided in relation to the arrangement.

If that date is between 1 July 2020 and 31 December 2020 the report must be made on or before 30 January 2021.

If the arrangement started between 25 June 2018 and 30 June 2020 the report must be made on or before 28 February 2021.

In order to make a report, the person with the reporting requirement must register with HMRC. Reporting is done through HMRC's online services.

Useful guides on this topic

DAC6: Do you need to make a report?

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