Whilst the European Commission decided on Friday 8 May 2020 to defer the DAC6 filing deadlines, and the Council of the European Union adopted a directive to that effect on 19 June 2020, permitting a deferral of up to six months, the UK Government has only recently announced deferring the first reporting deadlines. This is good news, as otherwise reporting obligations would have started on 1 July 2020.
For historic transactions where the first step in implementation was taken between 25 June 2018 and 30 June 2020, reports must be made by 28 February 2021, instead of the original deadline of 31 August 2020.
For arrangements which, for example, were made available for implementation between 1 July 2020 and 31 December 2020, reports must be made within the period of 30 days beginning on 1 January 2021 (and not the 30 day period commencing on 1 July 2020, as originally proposed).
Arrangements which become reportable on or after 1 January 2021 must be reported as normal, i.e. within 30 days.
The Government will amend the Regulations to give effect to this deferral. The amended Regulations may not be in force by 1 July 2020, but no action will be taken for non-reporting during the period between 1 July and the date the amended Regulations come into force.