DAC6 EU Mandatory Disclosure Requirement

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It is now over a year since reporting under DAC6 commenced across the EU.

What have we learned from this first 15 months of mandatory disclosure reporting?

The EU Mandatory Disclosure Reporting directive was implemented in 2018 and applies to all reportable cross-border arrangements implemented after 25 June 2018. The first reporting was due to commence in July 2020 but due to delays arising from the Covid-19 Pandemic, reporting was deferred in most EU Member States until January 2021. 

The Directive sets out various Hallmarks defining different types of cross-border arrangements which are reportable by intermediaries and Taxpayers to the tax authorities. Across the EU, Individual tax authorities have interpreted these rules in sometimes varying ways.