Tax

EU mandatory disclosure requirement

A new EU Directive (DAC 6) requires cross-border arrangements to be disclosed to the tax authorities where certain requirements are met. Failure to comply can result in penalties. We can assist you in implementing effective processes to ensure all reportable cross-border arrangements are identified and managed.

A cross-border arrangement is an arrangement that concerns more than one Member State, or that concerns a Member State and a third country (i.e. purely domestic arrangements should not fall within the Directive). A cross-border arrangement is reportable only if it has certain characteristics or features, known as “hallmarks”. These hallmarks are intended to limit the application of the regime to only those transactions for which there is a potential risk of tax avoidance.