On 30 June 2020, the Dutch State Secretary of Finance (the " State Secretary ") issued official guidance (" Guidance ") on the Dutch implementation of the European Union (" EU ") rules on mandatory disclosure and exchange of cross-border tax arrangements (" DAC6 ").

2020年11月25日 · Since most EU Member States have transposed definitions of hallmarks into their domestic mandatory disclosure regime in line with DAC6, we provide an overview in which we outline the different hallmarks as defined in 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.

On 25 June 2018, the Council of the European Union formally adopted new mandatory disclosure rules (“MDRs”) for qualifying intermediaries and relevant taxpayers, the latest in a series of EU initiatives in the field of automatic exchange of information in tax matters.

EU rules - commonly known as "DAC 6" - under the Directive on Administrative Cooperation require intermediaries and in some cases taxpayers to report a wide range of transactions to tax authorities from July 2020 – including transactions entered into from 25 June 2018.

By bringing these different skill sets together, we can help you and your organization understand DAC6, and the broader tax policy context, and implement effective controls and processes to ensure all reportable cross-border arrangements are proactively identified and managed.

DAC6, the EU directive on cross-border tax arrangements, came into force on 25 June 2018. This directive increases transparency requirements cross-border arrangements and prevents against aggressive tax planning. Businesses headquartered in or trading within the EU will need to ensure compliance with DAC6 from 25 June.

2021年6月7日 · One of the main purposes of “DAC6” is to enable EU member states to react promptly to harmful tax practices, notably by increasing the effectiveness of tax audits in international matters, including with respect to transfer pricing—which has been subject to increasing focus recently.

Under this new law tax intermediaries are required to report certain cross-border arrangements that contain at least one of the hallmarks as defined in DAC6. DAC6 contains five different hallmark categories that represent an indication that a …

Council Directive (EU) 2018/822 amending Directive 2011/16/EU (“DAC 6”) as regards mandatory automatic exchange of information in the field of taxation in relation to reportable cross-border arrangements, provides for mandatory disclosure of cross-border arrangements by intermediaries or taxpayers to the tax authorities and mandates automatic ex...