A A Practitioner's Guide To International Tax Information Exchange Regimes

DAC6, TIEAs, MDR, CRS, and FATCA

Grahame Jackson, Harriet Brown

• Publisher: Spiramus Press
• Year: 2021
• eBook ISBN: 9781913507244
• Edition: 0
• Topic: Business
• Subtopic: Taxation
• Index: Business

The recent introduction of the Directive on Administrative Cooperation in the field of taxation 6 (DAC6) and mandatory disclosure regimes by many jurisdictions have led to a large number of professionals potentially being required to disclose information in relation to their clients' arrangements. The authors analyse the operation of the various automatic exchange of information regimes which have been introduced in the last five years including the OECD common reporting standards DAC6 and MDR. They set them in their historical context as well as giving a technical analysis of the regimes. They focus on the guidance offered by the Irish and UK tax authorities with reference to other guidance in Europe and beyond, where appropriate.

Table of contents

• Contents
• Acknowledgements
• Guidance Abbreviations
• Introduction
• 1. History and Context
• 2 Types of Exchange
• 3 Interpretation
• 4 Disclosure of Tax Avoidance Schemes (‘DOTAS’)
• 5 Foreign Account Tax Compliance Act - FATCA
• 6 CRS
• 7 The Directive on Administrative Cooperation 6 (‘DAC6’) and the Mandatory Disclosure Regime (‘MDR’)
• 8 DAC6 Definitions
• 9 The Hallmarks and Reporting
• 10 MDR
• 11 TIEAs and Exchange Under Double Tax Treaties
• Index