All countries have issued DAC6 laws to implement the directive into local law (for Cyprus and Spain, the laws are draft, all other EU Member States have final laws in place).
- The reporting deadlines for all EU Member States (including UK) excluding Austria, Germany, and Finland are as follows.
- The reporting on ‘legacy cross-border tax arrangements (i.e. those with a first step of implementation between 25 June 2018 and 30 June 2020) must take place by 28 February 2021;
- The period of 30 days for filing information begins on 1 January 2021 if the triggering event for new arrangements took place between 1 July 2020 and 31 December 2020;
- For new arrangements arising on or after 1 January 2021, there is an automatic 30 day filing deadline in place starting on the date of the triggering event for the arrangement.
- The date for the first exchange of information between Member States on reportable cross-border tax arrangements is 30 April 2021;
- There is an option to apply for an additional three month extension, subject to unanimous agreement by the Member States and depending on the COVID-19 situation.
- Most countries have not issued the DAC6 reporting XML schema nor opened their DAC6 reporting portals. However, Netherlands, Ireland, Sweden, Hungary and Poland have issued draft or final XML schema.
- For Austria, the tax administration has opened its portal to enable DAC6 reporting to be performed a few days ago.
- The reporting should be done via completion of a web based questionnaire (i.e. there is no requirement to upload an XML or similar file). Reporting is done via logging into the FinanzOnline portal (which is the normal portal used by taxpayers in Austria) and completing the reporting
- The Austrian tax administration will not levy any penalties for DAC6 filings completed by 31 October 2020 (i.e. the original deadline for legacy arrangements was 31 August 2020 whilst new arrangements with a triggering date between 1 July and 30 September 2020 should have been reported in advance of 31 October, but no penalties will be levied for those technical late filings).
- For Germany and Finland, DAC6 reporting is already live. The first reporting deadlines were 31 July 2020 (for new arrangements triggered on 1 July 2020) and 31 August 2020 (for legacy arrangements). There is an ongoing obligation to file reportings for new arrangements triggered post 1 July 2020 (with a 30 day reporting deadline from that triggering event):
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