The UK government has published legislation requiring taxpayers and their advisers to disclose details of certain cross-border arrangements to HMRC as part of the EU’s DAC6 rules. 

Despite not coming into effect until 1 July 2020, it is already clear that their “impact will be wide-reaching on both taxpayers and their advisers,” according to Stuart Crippin, partner and head of private client at Seddons.

This directive has been “a long time in the works”, having been first issued by the EU Council in May 2018. Andrew Seidler, a RSM tax partner, acknowledged the UK is “a little late” with its legislatio...