Share on LinkedInShare on LinkedIn

ARTICLE · 13 APRIL 2023

UK Mandatory Disclosure Rules Come Into Force

Osborne Clarke
Explore more from Osborne Clarke

The new UK mandatory disclosure rules (MDR), which came into effect on 28 March 2023, require taxpayers and advisers – which are referred to as "intermediaries" and include lawyers and accountants...

United KingdomTax
Veronica McMahon
Veronica McMahon
Erika Jupe
Erika Jupe
Andrew Goodman
Andrew Goodman

New regulations require in-scope tax advisers to report details of avoidance arrangements online in XML file format

The new UK mandatory disclosure rules (MDR), which came into effect on 28 March 2023, require taxpayers and advisers – which are referred to as "intermediaries" and include lawyers and accountants – with a UK nexus to report prescribed arrangements and structures to HMRC.

Broadly speaking, the prescribed arrangements are those that are designed to facilitate non-compliance through the use of Common Reporting Standard (CRS) avoidance arrangements and opaque offshore structures and are based closely on the Organisation for Economic Co-operation and Development's model rules. The new rules also include a "look back" period (to 25 June 2018) for reporting pre-existing arrangements that have been entered into and not already reported. HMRC introduced this one major change to earlier draft regulations in its long-awaited response to the consultation on

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

Frequently Asked Questions About IRS Clearance And Form 706-NA

UK executors and beneficiaries dealing with US assets face significant delays in obtaining IRS Transfer Certificates, with waiting times now extending to two or three years. This comprehensive FAQ addresses the critical questions surrounding Form 706-NA applications, US estate tax requirements, and the practical challenges of administering estates containing US shares and investments when the deceased was not a US citizen.
GlobalTax
Lester Aldridge LLP
Lester Aldridge LLP
Article

UK ‘Windfall’ Bank Tax Would Worsen An Already Complex System

UK banks face the prospect of a new windfall tax as campaigners push for additional levies on strong reported profits, while industry leaders warn of potential consequences for lending, investment, and the UK's position as a global financial centre. This analysis examines the practical implications of adding another layer to an already complex sector-specific tax regime that includes corporation tax, banking surcharge, and bank levy.
United KingdomTax
RPC
RPC
Article

Tribunal Limits HMRC's Schedule 36 Powers In Transfer Pricing Case

When HMRC issued an information notice demanding a UK subsidiary's US parent company financial statements in a transfer pricing enquiry, the First-tier Tribunal had to determine whether such documents were reasonably required and whether the subsidiary had the power to obtain them. The case examines the boundaries of HMRC's information-gathering powers and the practical limits of corporate group relationships.
European UnionTax
RPC
RPC
Article

Transfer Pricing Enquiries: HMRC’s Approach And Recent Cases

Transfer pricing litigation in the UK has historically been rare, but recent procedural cases reveal HMRC's increasingly aggressive approach to enquiries. With average enquiry durations now exceeding 40 months and transfer pricing yield surging to £3.4bn, understanding the legal boundaries of information requests and closure notice applications has become critical for multinational groups facing contentious disputes.
United KingdomTax
Macfarlanes LLP
Macfarlanes LLP