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Cross-Border Transactions HMRC

Dechert LLP

Some Good News at Last: The Government Substantially Restricts DAC6 Reporting Obligations for UK Intermediaries

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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

Proskauer - Tax Talks

Narrowing of UK intermediaries’ DAC 6 reporting requirements

Proskauer - Tax Talks on

On 30 December, the UK government laid regulations that will significantly reduce the type of cross-border arrangement that will need to be reported by UK intermediaries under the so-called DAC 6 rules on 31 January 2021 and...more

Proskauer Rose LLP

UK Tax Round Up - June 2020

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UK COVID-19 Developments - HMRC updates its trading activities guidance - HMRC has updated its guidance at BIM48000 regarding how legislation and case law should be applied where a business makes changes to its...more

Dechert LLP

DAC6: Approval of six month extension to the reporting timetable

Dechert LLP on

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

White & Case LLP

DAC6 reporting delay proposed by EU Commission due to COVID-19

White & Case LLP on

DAC6 summary - Council Directive 2018/822 – known as DAC6 – is the sixth amendment to the EU Directive on Administrative Cooperation 2011/16/EU. DAC6 is aimed at providing the tax authorities with a “warning system” in...more

McDermott Will & Emery

How CCO Reasonable Prevention Procedures Can Help You Mitigate DAC6 Penalties

McDermott Will & Emery on

Corporate criminal offences (CCOs) under Part 3 Criminal Finances Act 2017 (CFA) are increasingly coming under the spotlight of the UK tax authorities. In a 10 February 2020 press release published in response to a Freedom of...more

Katten Muchin Rosenman LLP

UK Regulations Implementing EU Tax Anti-Avoidance Disclosure Laws Finalised

KEY POINTS - The UK Regulations, finalised on 13 January 2020, will only apply in relation to direct EU taxes. - The Legal Professional Privilege exemption is still unclear. - Penalties have been capped at £5,000. ...more

Katten Muchin Rosenman LLP

New EU-Wide Tax Anti-Avoidance Law Introduces Sweeping Disclosure Requirements

Key Points - Coming into force on 1 July 2020, EU DAC6 Regulations will require intermediaries in certain cross-border arrangements to disclose activity to tax authorities. - The DAC will apply retroactively to affected...more

Proskauer Rose LLP

UK Tax Round Up - August 2019

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UK Case Law Developments - Valid notice crucial to tax indemnity claim - The Court of Appeal (CA) decision in Stobart Group Ltd v Stobart and another is a cautionary tale for any purchaser who, following the...more

Dechert LLP

HMRC’s Implementation of EU Mandatory Tax Disclosure Rules

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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

Womble Bond Dickinson

The EU’s Contingency Plans for Customs & the Export of Goods in a “No Deal” Brexit

Womble Bond Dickinson on

The European Commission has published its Contingency Action Plan for a “No Deal” Brexit. The contingency plan seeks to mitigate significant adverse effects, but the Commission's paper emphasizes...more

Dechert LLP

Brexit: UK Customs Issues "Call for Action" to Businesses

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HM Revenue and Customs (HMRC) has issued a letter to 145,000 UK businesses setting out actions they need to take now to prepare for the “unlikely event of the UK leaving the EU without a deal.” More substantial steps may be...more

Pillsbury Winthrop Shaw Pittman LLP

EU: “Hard” Brexit Would Come with Border Friction and Costs

The European Union has published a technical note warning of dire consequences for businesses if the UK leaves the EU with no deal in place. The European Commission has warned companies across Europe to prepare for...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Delaware LLCs and UK Entity Classification: The Fallout From the Curious Case of George Anson"

Fundamental to any developed tax policy is knowing who the taxpayer is (or should be) with respect to any particular transaction. Although that can be relatively straightforward in purely domestic situations, a cross-border...more

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