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DAC 6 cross-border reporting obligations

  • Poland
  • Tax planning and consultancy - DAC6


Council Directive (EU) 2018/822 (DAC 6) was published on 25 May 2018 and is the sixth directive to amend Directive 2011/16/EU ( This latest amendment is directed at the mandatory exchange of information in tax in relation to reportable cross-border arrangements and looks set to introduce wholesale changes across Europe in the area of intermediary and taxpayer disclosure. In essence, DAC 6 requires intermediaries or taxpayers to disclose cross-border arrangements when certain ‘hallmarks’ that point toward potential tax-avoidance are present.

Read the article co-authored by Brendan Moran, Ed Griffiths and Anna Derdak (head of tax at the Warsaw office) that gives an overview of DAC 6, the status of its implementation in the UK and some insights from the early adoption in Poland where the authorities have been ahead of the curve by bringing in some of the key provisions sooner than required. It is broadly based on the UK disclosure of tax avoidance schemes (DOTAS) rules but could be much wider in scope. This is likely to be an important issue for intermediaries and taxpayers after it has been fully implemented across Europe. Further, the future reporting obligations will date back to 25 June 2018, so it is already a live issue, even though not yet domestically implemented in most member states.

Article has been published in Taxation Magazine >