Chapter IEIM659050

Published date25 April 2016
Record NumberIEIM659050

Some arrangements which are reportable under DAC 6, in particular arrangements that are reportable under Hallmarks D1 and D2, may also be reportable under other regimes including anti-money laundering legislation. Where a suspicious activity report (SAR) has been made under such legislation, it can be a criminal offence to tip off the person about whom the report was made. This helps to avoid destruction of evidence and prevents investigations from being prejudiced. Where a DAC 6 report is made in relation to an arrangement, an intermediary is normally required to pass the Arrangement Reference Number (ARN) onto other intermediaries and relevant taxpayers. However, in circumstances where passing on the ARN might make a person aware that an SAR has been made, and...

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