Mandatory Disclosure Rules Reporting

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.

HMRC now have four pages on their website to help taxpayers report under the new rules:

• Check if you need to tell us about an arrangement;
• Register for the MDR service;
• Report an arrangement through MDR; and
• Use the schema and supporting documents to report.

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.

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

For further information please contact:

• Sharon Baynham