Who does DAC6 apply?

Inhaltsverzeichnis:

1. Who does DAC6 apply?
2. What is a DAC6 filing?
3. Who needs to report DAC6?
4. What does DAC6 mean?
5. What DAC6 means?
6. What is EU directive DAC6?
7. What does DAC6 stand for?
8. Can an intermediary rely on reports from other intermediaries?
9. What is the main benefit test DAC6?
10. What is the purpose of DAC6?
11. How many categories of Hallmark exist in the tax intermediaries directive?
12. Does DAC6 apply to Switzerland?
13. Which countries have implemented dac6?
14. What dac6 means?

Who does DAC6 apply?

DAC6 applies to any person (including an individual, partnership, company or other legal entity) operating in the EU or with interests in the EU. So it could apply to multinational companies and also applies to intermediaries such as law firms, accountants, banks and financial advisors.

What is a DAC6 filing?

DAC6 (Directive 2018/822) is a new EU mandatory disclosure regime that imposes mandatory reporting of cross-border arrangements. It affects at least one EU Member State that falls within one of several categories or “hallmarks”.

Who needs to report DAC6?

The primary reporting obligation under DAC6 lies with an EU-based intermediary, which is defined as any person who designs, markets, organizes or makes available for implementation, or manages the implementation of a reportable cross-border arrangement.

What does DAC6 mean?

EU Directive on administrative cooperation The sixth version of the EU Directive on administrative cooperation (DAC6) aims to provide Member States tax authorities with additional information in order to assist them to more rapidly close perceived loopholes in tax legislation and harmful tax practices.

What DAC6 means?

“DAC 6” stands for the Directive on Administrative Cooperation in (direct) taxation in the EU, volume 6. ... DAC 6 is the part of the DAC series which provides for mandatory disclosure of reportable cross-border tax arrangements (RCBAs).

What is EU directive DAC6?

DAC6 aims at transparency and fairness in taxation. ... DAC6 applies to cross-border tax arrangements, which meet one or more specified characteristics (hallmarks), and which concern either more than one EU country or an EU country and a non-EU country.

What does DAC6 stand for?

Directive on cross-border tax arrangements The EU Council Directive 2011/16 in relation to cross-border tax arrangements, known as DAC6, has been in force since . DAC6 aims at transparency and fairness in taxation.

Can an intermediary rely on reports from other intermediaries?

While intermediaries may generally rely on a report reference number provided by a promoter of an arrangement as evidence of a report having been filed, they will not be able to rely in the same way on a report being filed by another service provider, unless they can somehow assure themselves that the information ...

What is the main benefit test DAC6?

The test is met if 'the main benefit or one of the main benefits which, having regard to all relevant facts and circumstances, a person may reasonably expect to derive from an arrangement is the obtaining of a tax advantage'.

What is the purpose of DAC6?

DAC6 is designed to give EU tax authorities early warning of new cross-border tax schemes. It requires tax authorities to be notified of cross-border tax arrangements satisfying certain 'hallmarks'. The tax authorities will then automatically exchange the information with other relevant EU tax authorities.

How many categories of Hallmark exist in the tax intermediaries directive?

five hallmarks The DAC 6 Hallmarks are broad categories setting out characteristics identified as potentially indicative of aggressive tax planning. More specifically, if a transaction or an arrangement contains at least one of the five hallmarks, then it must be reported to the appropriate regulatory authority.

Does DAC6 apply to Switzerland?

DAC6 requires the disclosure of certain cross-border tax planning arrangements to the local tax authorities. While the rules do not apply in Switzerland directly, Swiss intermediaries may be affected if they have operations or otherwise provide services in any EU country.

Which countries have implemented dac6?

Legislation passed Legislation has been passed in Austria, Belgium, Bulgaria, Croatia, Denmark, Estonia, Finland, France, Germany, Hungary, Ireland, Lithuania, Malta, The Netherlands, Poland, Slovakia, Slovenia, United Kingdom.

What dac6 means?

“DAC 6” stands for the Directive on Administrative Cooperation in (direct) taxation in the EU, volume 6. ... DAC 6 is the part of the DAC series which provides for mandatory disclosure of reportable cross-border tax arrangements (RCBAs).