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Mandatory disclosure rules and DAC 6

Practical guidance and support on tax disclosure around the world, including the UK's Mandatory Disclosure Rules and DAC 6.

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DAC 6 and OECD disclosure in brief

An overview of the EU and OECD Mandatory Disclosure Regimes in the context of UK reporting. This 20-min webinar covers what is DAC 6; who it affects; what types of arrangements will be caught; what the reporting requirements are and potential penalties.
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ICAEW's Tax Faculty provides expert support and insights into the latest developments in the UK's tax system.

Features and articles

EU Council reaches agreement on exchange of information for crypto assets and advance tax rulings for high-net-worth individuals
  • Article
  • 26 May 2023
The unanimous agreement paves the way for greater co-operation between member states to reduce opportunities for tax avoidance and tax fraud using crypto assets, by amending the directive on administrative co-operation in the area of taxation (DAC).
Tax news in brief 19 April 2023
  • Article
  • 19 Apr 2023
Highlights from the broader tax news for the week ending 19 April 2023, including: closure of online VAT return; PAYE direct debits; TRS reporting requirements; interest rate increase for discounted gift trusts; NMW campaign; Finance Bill amendment for R&D; closure of the DAC6 reporting service; and Tax Administration and Maintenance Day.
Tax news in brief 8 February 2023
  • Article
  • 07 Feb 2023
Highlights from the broader tax news for the week ending 8 February 2023
Mandatory disclosure rules replace DAC 6 in the UK
  • Article
  • 24 Jan 2023
Cross-border tax avoidance arrangement disclosure rules devised by the OECD (known as the mandatory disclosure rules, or MDR) will enter into force in the UK on 28 March 2023. Arrangements entered into on or after this date must be reported to HMRC under this regime.
MDR: ICAEW concerned over backdated reporting
  • Article
  • 09 Feb 2022
ICAEW’s Tax Faculty welcomes that the new rules designed to implement the OECD’s model mandatory disclosure regime are targeted at those arrangements that might allow or facilitate tax evasion. However, it has concerns over the backdated reporting requirements, which exceed those of the predecessor DAC 6 legislation.
HMRC expands reporting portal for mandatory disclosure rules
  • Article
  • 16 Mar 2021
It is now possible to manually report arrangements between the UK and EU member states under the mandatory disclosure reporting regime (commonly known as DAC 6).
Final call for first UK DAC 6 reporting deadline
  • Article
  • 27 Jan 2021
27 January 2021: The first reports under the UK’s mandatory disclosure regime, based on the EU’s DAC 6, are due on 30 January 2021. ICAEW’s Tax Faculty provides a reminder of the rules.
HMRC launches online tool for mandatory disclosure reporting
  • Article
  • 19 Jan 2021
19 January 2021: HMRC has opened its portal to allow taxpayers and intermediaries to report arrangements that fall under OECD mandatory disclosure rules, but agent functionality is not yet available.

Recordings

DAC6 the OECD Mandatory Disclosure Regimes in brief
  • Webinar
  • 15 Feb 2021
An introduction to DAC6 and the OECD Mandatory Disclosure Regimes in the context of UK reporting.
Exclusive The UK and DAC6 post-Brexit - where are we now?
  • Webinar
  • 19 Jan 2021
In this webinar ICAEW Tax Faculty Business Tax Manager, Richard Jones, is joined by Jo Myers and Ariana Kosyan of EY to get you up to speed with the current position and discover the likely future shape of disclosure requirements for UK advisers and their clients.

Bloomsbury Accounting and Tax Service

Eligible firms have free access to Bloomsbury Professional's comprehensive online library, comprising around 80 titles from some of the country's leading tax and accounting subject matter experts. Find out who is eligible and how you can access the Accounting and Tax Service.
Exclusive The regulation of tax avoidance
  • eBook chapter
  • 2024
  • Hartley Foster, Adrian Shipwright
  • Revenue Law - Principles and Practice
A chapter on the various anti-avoidance rules which apply in the UK. Includes sections on the Disclosure of Tax Avoidance Schemes regime, the indirect tax rules, accelerated payment and follower notices, the Promoters of Tax Avoidance Schemes rules, and DAC6 and mandatory disclosure rules.
Exclusive EU DAC 6 – the UK’s former EU Mandatory Disclosure regime
  • eBook chapter
  • 2023
  • John Hiddleston, Azets
  • Automatic Exchange of Information Handbook
A chapter giving an overview of the UK’s DAC 6 regulations, which were revoked with effect from 28 March 2023, at which point they were replaced by new OECD MDR regulations.
Exclusive OECD MDR – the OECD Mandatory Disclosure regime
  • eBook chapter
  • 2023
  • John Hiddleston, Azets
  • Automatic Exchange of Information Handbook
A chapter covering the new Mandatory Disclosure Rules which came into force in the UK on 28 March 2023, implementing OECD MDR. These replaced the previous mandatory disclosure regulations, which were based on the EU’s DAC 6 rules.
Exclusive DAC 6
  • eBook chapter
  • 2021
  • Julian Hickey, Adrian Shipwright
  • Law and Regulation of Tax Professionals
A chapter covering the law and associated practical matters concerning DAC 6 compliance for tax professionals.
Terms of use

You are permitted to access, download, copy, or print out content from eBooks for your own research or study only, subject to the Acceptable usage terms.

eBooks

The Library & Information Service provides a collection of eBooks as a benefit of membership. Please log in to access these titles. If you are unable to access an eBook, please see our Help and support or contact library@icaew.com.

Exclusive Mandatory disclosure rules
  • eBook
  • 2023
  • Georg Kofler [and others]
  • IBFD
Contains 39 national reports from experts in international tax law with strong knowledge in the OECD/G20 BEPS Project and EU developments where they discuss their countries' objectives and experiences regarding the impact and implementation of MDR.
Exclusive A practitioner's guide to international tax information exchange regimes
  • eBook
  • 2021
  • Grahame Jackson, Harriet Brown
  • Spiramus
The authors analyse the operation of the various automatic exchange of information regimes which have been introduced in the last five years, including the OECD common reporting standards DAC6 and MDR.
Terms of use

You are permitted to access, download, copy, or print out content from eBooks for your own research or study only, subject to the terms of use set by our suppliers and any restrictions imposed by individual publishers. Please see individual supplier pages for full terms of use.

Articles and books in the ICAEW Library collection

The collection of the ICAEW Library & Information Service includes a range of articles, books and reports on mandatory disclosure rules and DAC 6. A selection of books on this topic is set out below.
A practitioner's guide to international automatic tax information exchange regimes: DAC6, TIEAs, MDR, CRS, and FATCA
  • Library book
  • 2021
  • H. Brown, G. Jackson
  • Spiramus
This book serves as a practical guide to the various automatic exchange of information regimes which have been introduced in recent years, including the OECD common reporting standards DAC6 and MDR.
Automatic exchange of information handbook
  • Library book
  • 2021
  • J. Hiddleston
  • Bloomsbury Professional
This title takes an in-depth look at the automatic exchange of information rules and legislation applicable within the UK. It covers the requirements of the OECD Common Reporting Standard (CRS), the US Foreign Account Tax Compliance Act (FATCA), and the EU's DAC 6 rules.

To find out how you can borrow books from the Library please see our guide to borrowing books.

You can obtain copies of articles or extracts of books and reports through our document supply service.

External resources

Some resources that we link to may pre-date the latest amendments to the relevant tax regulations. While these links contain useful information, please treat them with appropriate caution.

Check if you need to tell HMRC about a cross-border arrangement
  • Website
  • 03 Feb 2023
  • HMRC
Guidance on reportable cross-border arrangements under the mandatory disclosure rules (MDR). It covers what arrangements need to be reported, who needs to report, when they must inform HMRC, and how to register and report.
Mandatory Disclosure Rules legislation — HMRC internal manual
  • Website
  • 18 Sep 2023
  • HMRC
Internal guidance from HMRC regarding the UK’s legislation implementing MDR, which came into force on 28 March 2023. These replaced similar regulations based on the EU's DAC 6 rules.
Administrative cooperation in the field of taxation: Summary of EU Directive 2011/16
  • Website
  • 26 Oct 2020
  • EUR-Lex
Official summary of DAC6 with key points highlighting the scope and requirements of the Directive. It includes links to the legislation and amendments.
Model Mandatory Disclosure Rules for CRS Avoidance Arrangements and Opaque Offshore Structures
  • Website
  • 09 Mar 2018
  • OECD
This report presents the text of the OECD model rules, alongside an overview of key elements and commentary on definitions, disclosure requirements and penalties.
OECD Mandatory Disclosure Rules
  • Website
  • 05 Oct 2015
  • OECD
The report gives an overview of mandatory disclosure regimes in different jurisdictions and sets out a modular framework for countries implementing mandatory discloure rules, with specific recommendations for rules targeting international tax schemes.

ICAEW accepts no responsibility for the content on any site to which a hypertext link from this site exists. The links are provided ‘as is’ with no warranty, express or implied, for the information provided within them. Please see the full copyright and disclaimer notice.

Further support

TAXconnect
  • Listing
  • 06 Mar 2015
Search for a consultant to help you with a specific technical tax problem. TAXconnect works on a telephone ‘hotline’ system, whereby consultants offer advice to fellow Tax Faculty members on tax problems for a nominal fee.
Tax Faculty
  • Hub page
  • 10 May 2018
Find out more about the Tax Faculty and upcoming events. Faculty members can access exclusive content, including TAXline, TAXguides, webinars, representations and support schemes.
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Information

Some of the content on this web page was provided by the Chartered Accountants’ Trust for Education and Research, a registered charity, which owns the library and operates it for ICAEW.