The Amendment to Directive 2011/16/EU on administrative cooperation in the field of taxation (known colloquially as “DAC6”) is the EU version of the OECD’s Mandatory Disclosure Requirements (“MDRs”) for intermediary reporting on so-called “aggressive” tax planning arrangements with a cross-border component. DAC6 specifies sets of characteristics indicative of aggressive tax planning–labelled “Hallmarks”–and compels the disclosure of any cross-border transactions or other activities evidencing these Hallmarks. DAC6 mandates that for any reportable arrangements, the EU intermediaries involved in the transaction–such as tax advisors, lawyers, accountants and fiduciaries–or the taxpayers affected by it (if no intermediary qualifies) must:
Retroactive reports for reportable cross-border arrangements (RCBAs) executed between 25 June 2018 and 30 June 2020 are due in bulk shortly after the onset of the regime in each EU Member State.
- Disclose specified information
- About the arrangement and the parties involved in it (including both other intermediaries and clients)
- To their local competent authority
- Within 30 days
- For exchange on an automatic basis with other EU member states
Retroactive reports for reportable cross-border arrangements (RCBAs) executed between 25 June 2018 and 30 June 2020 are due in bulk shortly after the onset of the regime in each EU Member State.
Millen Tax & Legal offers an array of DAC6- and MDR-related services, including:
- Evaluation of overall operations to determine potential intersections with DAC6/MDRs regimes
- Review and refinement of policies, procedures and related systems to cope with DAC6/MDR reporting
- Analysis of specific arrangements for reportability
- Support in report preparation and submission
- Preparation of client communication materials
For more information on DAC6, please refer to the Millen Tax & Legal blogs, publications and presentations
Trusts & Trustees article: Forming financial intermediaries into a fifth column - MDRs and DAC6 for fiduciariesLiechtensteinische Steuerkonferenz 2018 (Liechtenstein Tax Conference 2018)What the EU's DAC6 means for Swiss & Liechtenstein fiduciaries |
ALL the BlueBridge WebinarsDAC6 reporting dates delayed for a further three months? It depends... |
STEP/NYSBA's Annual International Estate Planning InstituteDAC6 reporting delayed for an initial three months |
To complement our consulting services, for your EU DAC6 and OECD MDR reporting needs, Millen Tax & Legal proudly presents
BlueBridge: Your Integrated DAC6 & MDR Reporting Solution
At BlueBridge, we offer a complete and integrated DAC6 & MDR reporting solution. We unite tax technical skills with operational expertise in order to cope with a demanding reporting regime and its extremely short, rolling reporting period. We provide Swiss quality, precision and reliability, throughout all stages of reporting, which is further enhanced by our Swiss commitment to data security. Let BlueBridge assume your full DAC6 disclosure burden so that you can focus your team’s resources on core business matters with complete peace of mind.
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