The main arrangements requiring to be disclosed to the UK tax authorities are around:
- structures created to avoid disclosure of income and gains
- structures created to disguise who the beneficial owners are
As an example of the second point, if the beneficial owners are unidentifiable say by the use of nominee shareholders or control is exercised indirectly rather than by formal ownership.
This is a significant reduction in tax compliance in the UK but international groups will still need to consider DAC6 and the reporting requirements as they are likely to have to make disclosures for their companies based in the European Union.
We have previously covered the DAC6 disclosure requirements in two separate blogs, which can be accessed here:
The next step
If you require further support or advice in relation to the application of DAC6 to your specific situation, please contact your usual UHY adviser.