(This note is not part of the Regulations)
The Regulations amend the International Tax Compliance Regulations 2015 (“the principal Regulations”) which give effect to agreements and arrangements reached between the United Kingdom and other jurisdictions to improve international tax compliance.
The Regulations omit references to the European Union Council Directive on Administrative Cooperation (2011/16/EU) (“the DAC”) and arrangements entered into by the EU relating to the implementation of the Common Reporting Standard for Automatic Exchange of Financial Account Information between member States and other territories as neither the DAC nor those arrangements will apply to the United Kingdom after the end of the transition period. The Regulations also make consequential amendments to replace definitions that rely on the DAC with equivalent definitions in the CRS and specify dates that are set out in the DAC but not the CRS to maintain the effect of those provisions after the end of the transition period.
A Tax Information and Impact Note covering the International Tax Compliance Regulations 2015 was published on 18th March 2015 and is available on the HMRC website at https://www.gov.uk/government/publications/tax-administration-regulations-to-implement-the-uks-automatic-exchange-of-information-agreements. It remains an accurate summary of the impacts that apply to this instrument.