EU Mandatory Disclosure Regime


The Council Directive 2011/16/EU (DAC) provides for the exchange of taxpayer information between the tax administrations of EU Member States. The DAC was amended by Council Directive (EU) 2018/822 (DAC6) to introduce a mandatory disclosure regime for certain cross-border transactions.

The information obtained will enable Member States to react promptly against harmful tax practices by:

  • closing loopholes in legislation
  • undertaking risk assessments
  • carrying out tax audits.

The regime comprises two steps:

  1. Intermediaries and, in certain circumstances, taxpayers, provide information regarding reportable cross-border arrangements to the tax authorities of Member States. This includes a requirement to file information in relation to arrangements implemented between 25 June 2018 and 30 June 2020. 
  2. Tax authorities exchange the information they receive with all other Member States.  

Next: When and how is the information exchanged