Mandatory Disclosure Rules Reporting

MDR reporting came into effect on 28 March 2023, whilst DAC6 regulations have been repealed.

MDR reporting came into effect on 28 March

New rules for the reporting of Common Reporting Standard (CRS) avoidance arrangements and opaque offshore structures under Mandatory Disclosure Rules (MDR) came into force in the UK from 28 March 2023. On that date HMRC published two further pieces of guidance, to complete their online service for reporting, and provided an update on reporting under DAC6. Further guidance is expected to be published in the next few months, following informal consultation, to address some remaining areas of detail where clarification is still needed.

Reporting under MDR

HMRC are actively looking for feedback to help them improve the service and taxpayers will be given the option to share feedback when they register or report for MDR.

Reporting under DAC6

HMRC have confirmed that the DAC6 service will remain open until 31 May 2023. This is for reporting any arrangements that are relevant before 28 March 2023 and previous reports that require amendments or corrections.

Taxpayers must finalise any DAC6 reports, and any amendments or corrections to previous DAC6 reports, by 31 May 2023.

The following arrangements should be reported through MDR and not DAC6:

  • Those made available on or after 28 March 2023; and
  • Those where assistance was provided on or after 28 March 2023