We use cookies on our website in order to make your visit more efficient and to offer you the most pleasant possible experience and to analyse the accesses to our website. We use Google Analytics for this purpose. Further information can be found in our DATA PROTECTION STATEMENT.

Cross-Border Tax Arrangements

14 November 2019

New reporting obligations retroactively starting 25 June 2018

On 25 June 2018 the Council Directive (EU) 2018/822/EU1 (also “DAC62) entered into force requesting taxpayers to proactively report to the tax authorities potentially tax-aggressive cross-border structures in case that certain “hallmarks” are met. The tax authorities of the EU Member States shall automatically and periodically exchange information on such reportable cross-border arrangements. The primary objective of the Directive is to enable legislators and tax authorities to identify aggressive tax practices in a timely manner and to take action against them. The Member States are obliged to incorporate the DAC6 requirements into national law by 31 December 2019.


1 Directive (EU) 2018/822 of the Council of 25 May 2018 „amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation in relation to reportable cross-border arrangements“, ABl. L 139 from 5 June 2018, p. 1   

2 DAC6, as this is the 6th amendment to the Directive on administrative cooperation in the field of taxation.