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Disclosure Requirements for Cross-border Tax Arrangements

Information for intermediaries

October 2019

New disclosure requirements under DAC 6

On 25 June 2018, the sixth amendment to the EU Directive on Administrative Cooperation (2011 / 16 / EU) on mandatory automatic exchange of information in the field of taxation in relation to reportable cross-border arrangements (“DAC 6“ for short) entered into force.

DAC 6 primarily requires intermediaries to report certain cross-border tax arrangements to the competent tax authorities.

The main objective of these Europe-wide disclosure requirements is to identify possible tax evasion and profit transfers promptly and combat “aggressive tax planning“ through greater transparency.

The scope of the Directive is very wide-ranging. It covers not only arrangements that are obviously aggressive, but also legal and common cross-border tax arrangements.

Intermediaries would be well advised to take appropriate precautions now and prepare for the upcoming disclosure requirements.

How can we support you?

We are always on hand to provide expert assistance with developing individual solutions to meet your disclosure obligations, both in Germany and across the international CMS organisation.

EU Mandatory Disclosure Regime (MDR)
Publication
Disclosure Requirements for Cross-border Tax Arrangements
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Authors

Portrait ofHeino Büsching
Dr. Heino Büsching
Partner
Hamburg
Portrait ofJörg Schrade
Jörg Schrade
Partner
Munich
Portrait ofMartin Mohr
Dr. Martin Mohr
Partner
Stuttgart
Portrait ofPhiline Lindner
Philine Lindner
Senior Associate
Hamburg
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