DAC 6 / MDR Radar

A new wave of reporting rules will be effective in the European Union on 1 July 2020, with retroactive effect to 25 June 2018.

These new requirements were introduced by the last amendments to the EU Directive on Administrative Cooperation in the field of taxation, commonly known as DAC 6.

It will soon be required to disclose all cross-border arrangements/structures meeting the criteria and hallmarks of DAC 6.

Although the implementing deadline of 31 December 2019 has already passed, only 21 countries have implemented these rules into their domestic legislation, while 6 countries are still at the implementation drafting stage. Greece has not yet unveiled its proposal to introduce the DAC 6 package into its legislative landscape.

On 24 January 2020, the European Commission sent formal notices to Belgium, Cyprus, Czech Republic, Estonia, France, Greece, Italy, Latvia, Luxembourg, Poland, Portugal, Romania, Spain, Sweden and the United Kingdom regarding the implementation of DAC 6. If these countries do not follow up on these formal notices in the next two months, the Commission should issue a reasoned opinion. However, there is no information published that reveals which aspects of the DAC 6 implementation the Commission is not satisfied with specifically.

 

 

Useful links:

Global Tax alert on tax intermediaries directive

Luxembourg Tax Alert on DAC 6 implementation

Text of the Council Directive (EU) 2018/822 of 25 May 2018 relating to reportable cross-border arrangements (DAC6)

Understanding DAC 6 - EU tax directive 2018/822 and its effects on cross-border tax arrangements

DAC 6 law voted by the Luxembourg parliament

 

Source:DELOITTE| Luxembourg Tax Alert |

 

 

 

 

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