Clifford Chance

The impact of DAC6 on securitisation structures

17 September 2020

The amendments to the EU Directive on Administrative Cooperation made in May 2018 were announced as a tool to give tax authorities greater visibility on aggressive tax planning. However, the drafting of the Directive and its implementation in the UK and throughout the EU is such that even standard transactions without any particular tax objective may be caught, giving rise to potentially wider reporting obligations than market participants had initially expected.

In this briefing, we review the requirements of DAC6, identify the features (or "hallmarks") that are most relevant for securitisation structures, and discuss what steps market participants can take to ensure compliance.

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