The portal for DAC 6 reporting to HM Revenue and Customs (HMRC) is now open, with the first reporting deadline falling on 30 January 2021.

The UK regulations implementing the EU Directive known as DAC 6 require lawyers and other ‘intermediaries’ to report certain cross-border arrangements within scope to HMRC.

Only relevant cross-border arrangements carrying one of the “D hallmarks” within the legislation now need to be reported. Read more about these hallmarks in HMRC’s International Exchange of Information Manual.

Reports need to be made by reference to various trigger dates for arrangements:

  • 30 January 2021 – if the relevant reporting trigger fell between 1 July 2020 and 31 December 2020
  • 28 February 2021 – if the first step in the implementation of a reportable arrangement was taken between 25 June 2018 and 1 July 2020
  • within 30 days – if the reporting trigger falls on or after 1 January 2021.