As previously reported, the UK has amended its implementing regulations for DAC6 reporting to effectively limit the scope of reporting to arrangements falling within the scope of Hallmark D, which is in line with the model Mandatory Disclosure Rules (MDR) developed by the OECD. Although it was originally assumed that this limited scope would apply for arrangements from 1 January 2021, UK HMRC has reportedly confirmed that the limited scope applies retrospectively from 25 June 2018. As such, n…