Information on reporting requirements imposed by DAC6

The disclosure requirements under DAC6 applies to both intermediaries and taxpayers in relation to certain EU cross-border arrangements exhibiting specifically defined “hallmarks” and in instances where the main or expected benefit of the arrangement is in the form of a tax advantage.

First reporting deadline is on the 30th of August 2020

The parties to which the DAC6 applies to need to understand the importance and impact of obligations imposed and the need to fully understand their obligations and plan appropriate measures and procedures in view of the envisaged first reporting deadline of the 30th of August 2020. This deadline is applicable for the retroactive reporting of qualifying cross-border arrangements implemented between the 25th of June 2018 and the 1st of July 2020. 

The DAC6 has been recently transposed into the domestic legislation and an analysis on its impact is currently on the way. Also in expectancy is the official guide which the Romanian tax authorities are required to publish together with the electronic reporting template.

Mazars, as a provider of tax consultancy services which falls under the mandatory disclosure requirements of DAC6 will be obliged to perform a review of the advice given to our clients in the period specified as well as going forward, assessing their qualification under the “hallmarks” and performing the subsequent reporting to the Romanian tax authorities.
Because of this development and this legal requirement, the engagement terms of our services agreements will be amended accordingly.

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