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
Dechert partnered with Getting the Deal Through and Law Business Research on their annual Market Intelligence Private Equity Guide. The 2020 Guide invites leading practitioners to reflect on evolving legal and regulatory...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
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
On Friday 8 May 2020, the European Commission announced a proposal to postpone by three months the initial reporting deadlines for “DAC6”, the incoming mandatory disclosure regime for potentially aggressive tax arrangements....more
5/15/2020
/ Coronavirus/COVID-19 ,
Cross-Border Transactions ,
Deferred Action ,
EU ,
European Commission ,
Filing Deadlines ,
Financial Institutions ,
Mandatory Disclosure Rules ,
Member State ,
Reporting Requirements ,
Time Extensions ,
UK
HMRC has released a consultation document in respect of its draft regulations implementing the EU mandatory tax disclosure rules that will apply from 1 July 2020 to intermediaries and relevant taxpayers in relation to...more
7/30/2019
/ Consultation Periods ,
Cross-Border Transactions ,
Disclosure Requirements ,
EU ,
Foreign Taxpayers ,
HMRC ,
Intermediaries ,
International Tax Issues ,
Legal Professional Privilege ,
Penalties ,
Tax Avoidance ,
Tax Evasion ,
Transfer Pricing ,
UK
The European Court of Justice (ECJ), in the case of Brisal, has determined on 13 July 2016 that national law which prohibits a non-resident taxpayer from deducting financing/operating costs from interest withholding tax...more
The Common Reporting Standard (“CRS”) will impose new investor due diligence and reporting obligations on funds and other financial institutions based in “early adopter” participating jurisdictions, with effect from January...more