Directive 2018/822/EU was published on the 25th of May 2018, amending Directive 2011/16/ U on administrative cooperation between Member States in the field of taxation.
In the European Union's effort to promote tax transparency and to suspend aggressive tax planning practices, the key role of business consultants (or intermediaries as defined in the Directive) is recognized, who are called upon, in principle, to provide tax authorities with information on any cross-border transaction in which they are involved in some way as long as that transaction has specific Hallmarks.
The Directive introduces the definition of the secondary intermediary which involves Credit Institutions.
Following the 1st of January 2021, reportable transactions must be filed within 30 days from when the arrangement was implemented.
The information to be disclosed includes the identities of the parties involved (such as name, tax residence), details of the declared cross-border arrangement itself as well as the distinctive features which make the cross-border arrangement declarable.
Information on DAC 6 issues can be found at the following link: