Strategizing Multinational Tax Risks

In response to prior comments, including additional clarification, HMRC has issued draft guidance for which comments are to be received by May 15, 2020.

With regard to penalties, which are a significant concern re: implementation and reporting of DAC6 reportable arrangements, there will be a “reasonable excuse” guideline.  This guideline will be supporting by the governance and documentation principles established in the reporting process.

EY’s Alert provides additional details on this recent development.

https://www.ey.com/en_gl/tax-alerts/uk-hmrc-issues-draft-guidance-on-mandatory-disclosure-regime-regulations