On 4 July 2022, the government published a consultation document calling for engagement in relation to proposed reforms to clarify who is entitled to benefit from sovereign immunity and also to restrict the availability of...more
On 20 July 2021 (or so-called “Legislation Day 2021”), amongst a raft of other items, the UK government published its response to its second consultation on proposals for a new legislative regime that will require large...more
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
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.
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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
The European Council has adopted new rules aimed at providing EU tax authorities with advance information in relation to aggressive cross-border tax planning. A failure to provide prompt disclosure of such arrangements could...more
In a previous article, we reported that draft legislation had been published to extend the scope of section 363A of the Taxation (International and Other Provisions) Act 2010 to ensure that alternative investment funds (AIFs)...more