Jurisdiction(s):
United Kingdom

Key definition

Tax arrangements definition

What does Tax arrangements mean? In legal practice, tax arrangements describes any steps, structure or planning put in place where, viewed objectively and having regard to all the circumstances, obtaining a tax advantage is the main purpose, or one of the main purposes. Arrangements include any agreement, understanding, scheme, transaction or series of transactions, whether or not legally enforceable. This wording is used in UK anti‑avoidance legislation, notably the General Anti‑Abuse Rule (GAAR) in the Finance Act 2013, and informs regimes such as DOTAS and the promoters of tax avoidance schemes rules. The test is objective and fact‑sensitive; if met, HMRC may...

UK DAC 6 (Archived): cross-border disclosure regime—Category D hallmarks, intermediaries’ and taxpayers’ duties, LPP, reporting deadlines, penalties, and replacement by OECD Mandatory Disclosure Rules (2023)

Published by a LexisNexis Tax expert

Practice notes

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ARCHIVED : This Practice Note has been archived and is not maintained. STOP PRESS :

This Practice Note is archived and no longer updated. As of 28 March 2023, the disclosable arrangements (dac 6) regime was superseded by the Mandatory Disclosure rules (MDR). The DAC 6 legislation and accompanying HMRC guidance have been withdrawn. As outlined here, the scope of the UK’s disclosure rules was materially narrowed from IP completion day (11 pm on 31 December 2020). The residual disclosure obligations were then wholly replaced on 28 March 2023 by new rules implementing the OECD MDR, as set out in The International Tax Enforcement (Disclosable Arrangements) Regulations 2023, SI 2023/38 (the MDR regulations). Although the DAC 6 Regulations, SI 2020/25, were revoked with effect from 28 March 2023, they continue to apply to arrangements entered into before that date. An arrangement put in place immediately before 28 March 2023 does not fall between the two regimes — it remains reportable under the DAC 6 rules in SI 2020/25, and the reporting system under DAC 6 stays open until 31 May 2023 to permit such reporting (on the basis that the time limit for reporting...

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Web page updated on 22/05/2026

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