28.02.2020

DAC 6: EU tax disclosure rules - Executive Summary

Key Facts

The “DAC 6” amends the Directive on Administrative Co-operation, provides for the mandatory disclosure of information on 'potentially aggressive tax planning arrangements‘ and introduces automatic exchange of information between relevant tax authorities of EU member states.

Tax authorities will be provided with an early warning mechanism on new risks of tax avoidance and thereby will be able to carry out audits more effectively.

Any intermediary or taxpayer connected to the EU would be affected.

What?

The Directive 2018/882/EU, commonly referred to as “DAC 6”, amends the Directive on Administrative Co-operation (2011/16/EU), provides for the mandatory disclosure of information on 'potentially aggressive tax planning arrangements‘ and introduces automatic exchange of disclosed information between relevant tax authorities of EU member states.

Why?

To provide tax authorities with an early warning mechanism on new risks of tax avoidance and thereby enable them to carry out audits more effectively, with the final objective of improving the functioning of the internal market by discouraging the use of aggressive cross-border tax-planning arrangements.

Who?

Any intermediary (or a taxpayer) who has a connection with the EU.

How?

The DAC 6 imposes mandatory reporting obligations by intermediaries or, in certain circumstances, taxpayers of cross border arrangements which meet certain “hallmarks”.

When?

The Directive is in force since 25 June 2018, the domestic implementation was due on 31 December 2019, and domestic regimes should be effective by 1 July 2020.
Reporting obligations are due 30 days after the arrangement is made available / is ready for implementation or first steps have been made (whichever occurs first).

Download the full document here.

Download Executive Summary

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