The E.U. Council Directive 2018/822 ("DAC6") provides
for the mandatory disclosure by intermediaries, or individual or
corporate taxpayers, to H.M.R.C. of certain cross-border
arrangements and structures that could be used to avoid or evade
tax and the mandatory automatic exchange of this information among
E.U. Member States. A cross-border arrangement is reportable if it
meets one or more hallmarks.
From January 2013, the E.U. introduced the Directive of
Administrative Co-operation and, over time, Directive of
Administrative Co-operation has evolved to include the automatic
reporting of various matters. It now includes directors' fees,
employment income, insurance premiums, pension income and income
from and ownership of immovable property.
