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.

If you would like to discuss more on this topic, please do reach out to our key contacts below.

Key Contacts

Brandi Caruso - Partner, Financial Services Tax 

Brandi heads Deloitte’s Financial Services Tax team in Switzerland and Liechtenstein. She has extensive expertise in advising the Swiss financial services industry on the implementation of U.S. and international transparency regimes (including QI, FATCA, Section 871(m), CRS, MDR and DAC6). Brandi leads the Financial Services Tax team efforts related to innovative technology solutions. Brandi is a U.S. Certified Public Accountant and has 20 years of experience with Deloitte and has worked in London and San Diego.

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Michael Grebe - Director, Financial Services Tax

Michael is a Director in the Financial Services Tax practice. He advises banks, trust companies, and insurers in relation to the interpretation and implementation of the global transparency related regimes. He has over ten years of experience in the financial industry covering a broad spectrum ranging from Process- over Project- to Product- Management. Prior to joining Deloitte, he led the FATCA and CRS implementation project for a global financial institution.

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Karim Schubiger – Director, Financial Services Tax 

Karim leads the Tax Transparency team in the Suisse Romande and Ticino markets within the Financial Services Tax & Legal practice, responsible for services related to QI, FATCA, CRS, 871(m) and DAC6. He is a technical advisor and subject matter expert to financial institutions in the banking, trust, and insurance sectors. Prior to joining Deloitte, Karim worked for eight years in support teams of Swiss banks, in particular in areas such as operations, project and change management as well as operational taxes.

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Robin King - Senior Manager, Financial Services Tax

Robin is a Senior Manager working in Financial Services Tax. He is currently advising leading Swiss universal and private banks, acting as subject matter expert in the area of QI, FATCA , CRS and DAC6. Robin is the author of several articles on CRS. Prior to joining Deloitte, he worked as a cross-border tax compliance expert at a Swiss private bank.

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