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Mandatory exchange of information in cross-border arrangements


On July 1, 2020 the EU Council Directive 2018/822 comes into force. Its provisions are to enhance tax transparency in the EU, discourage the taxpayers from entering into aggressive tax-planning strategies, and provide the EU tax authorities with additional tools to promptly react to harmful tax practices and close gaps in law.

DAC6 imposes an obligation to disclose to the tax authorities reportable cross-border arrangements (RCBA) on EU intermediaries or on EU taxpayers. The information reported to the local tax authorities will automatically be exchanged among all EU tax authorities.

In particular, DAC6 will have an impact of the Russian groups of companies that have presence in the EU. It is important to note that the new requirements are broadly worded and, therefore, may apply to a wide range of persons.

The provisions of DAC6 must be introduced into the national legislation of the EU countries by December 31, 2019.


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