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:
- 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.
- Tax authorities exchange the information they receive with all other Member States.
Next: When and how is the information exchanged