Executive summary
The United Kingdom (UK) tax authority, Her Majesty’s Revenue and Customs (HMRC) has circulated draft guidance on the application of the UK’s implementing legislation for the European Union (EU) Directive 2018/822 on the mandatory disclosure and exchange of cross-border tax arrangements (referred to as DAC6 or the Directive). The International Tax Enforcement (Disclosable Arrangements) Regulations 2020 (the UK Regulations), which implements the Directive in the UK, was laid befor…