The Government is deferring the first reporting deadlines under the International Tax Enforcement (Disclosable Arrangements) Regulations 2020 by six months. The Government will amend the Regulations to give effect to this deferral. However, HMRC has said that although the amended Regulations may not be in force by 1 July 2020, no action will be taken for non-reporting during any period between 1 July and the date that the amended Regulations come into force. There is therefore no expectation that reports will be made in July. HMRC will use the additional time to work with taxpayers and intermediaries on the IT reporting system.

The Law Society has published a useful Q&A on DAC 6 and legal professional privilege. See www.legalrisk.co.uk/news.

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