Check if you need to tell HMRC about a cross-border arrangement
Find out if you need to tell us about any reportable cross-border arrangements under the mandatory disclosure rules (MDR).
If you are involved in a cross-border arrangement you may have to tell HMRC about it. This could include:
- transfers of funds from an account in one country to an account in another country
- putting funds in an offshore trust
You are involved in a cross-border arrangement when you design, promote or manage it. This also applies where you offer help, support and advice or take part in the arrangement.
Who needs to tell HMRC
You need to tell us about a cross-border arrangement that you are involved in, if one of the following applies:
- you are a resident in the UK
- your business has its place of management in the UK
- your business is incorporated or registered in the UK
- your business operates in a branch or office located in the UK
There are exemptions from reporting, for example, if you would breach legal professional privilege by disclosing it to us, or if someone else has already reported the information.
When to tell us
You must tell us within 30 days from either the day:
- after the arrangement is made available
- the arrangement started
- after you offered help, support or advice about the arrangement
You must use whichever of these instances happens first.
Arrangements you must report
You must tell us about any cross-border arrangement that is:
- a Common Reporting Standard avoidance arrangement
- an Opaque Offshore Structure
To find out more about these types of arrangements, check ‘IEIM730000 — Common Reporting Standard avoidance arrangements and Opaque Offshore Structures’.
If you do not report your arrangement you may have to pay a penalty. Read ‘IEIM750000 — Penalties’ for more information.
If you have any queries, email: aeoi.enquiries@hmrc.gov.uk.
How to tell us
Use this service to report all mandatory disclosure rules (MDR) arrangements.
The deadline for reporting an arrangement that was made available from 25 June 2018 but was not reportable under DAC6 is 25 September 2023.
More information
You can also check the cross-border arrangements schema and supporting documents you’ll need for reporting under mandatory disclosure rules.
Updates to this page
Last updated 25 September 2023 + show all updates
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The reporting service can now be used to report all mandatory disclosure rules arrangements. A link to the reporting service has been added. Updated 'Arrangements you must report' section to include a link to HMRC's internal manual which provides more information about types of cross-border arrangements.
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The deadline for reporting an arrangement that was made available from 25 June 2018 but was not reportable under DAC6 has been updated from 24 September 2023 to 25 September 2023.
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The Mandatory Disclosure Rules (MDR) came into effect from 28 March 2023. You can now report using the new rules.
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First published.