HMRC's final guidance on DAC 6: a good first attempt?
Summer 2020 saw the publication of the UK tax authority's final guidance on the application of DAC 6. Helen Buchanan and John Tolman from our London tax team discuss the guidance in the briefing available at the link below.
The briefing highlights that taxpayers and advisers will find much that is welcome in the tone and approach of that guidance, but may have hoped for greater detail and for examples that could more easily be applied to novel situations. Taxpayers will also need to bear in mind that, however helpful the views in the guidance may be, they do not guarantee that other member states will take the same approach.
This briefing was originally published in Tax Journal on 2 October 2020.