The initial reporting of certain cross border arrangements under DAC6 was scheduled for the end of July 2020. Shortly before the DAC6 go-live date, the EU agreed on an optional six-month extension. Approximately one week after the EU agreement, some countries have communicated their position, others are silent, and at least one is not intending to provide an extension. We are here to help you keep an overview of the individual countries’ positions.
Since its inception, it was clear that the DAC6 implementation in the local member states would be a challenge. Extremely short deadlines led to member states struggling to publish final legislation and to provide useful guidance. As a result, intermediaries and relevant taxpayers had limited time to introduce new business- and reporting-processes and implement new IT requirements to ensure compliance. Deviations in the local implementations and the COVID-19 situation made a successful implementation in time for reporting nearly impossible for large multinational organisations.
For those reasons, most intermediaries and relevant taxpayers were relieved to learn that the EU granted an extension. Notably, however, this EU extension is not directly applicable to the individual member states and each member state must elect whether it will apply the extension. Several member states have announced a deferral of the local deadlines, but it is already clear that, at least to some extent, reporting deadlines will vary.
Deloitte is closely monitoring the reporting deadline developments and publishes the most recent updates on tax@hand. This overview is accessible under the following link.
In our view, effective use of the additional time granted will be key to a successful implementation.
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