EU Directive
DAC6 Regulations

Cross-border tax arrangements that meet one or more of the specified features are covered by DAC6.

Since June 25, 2018, the EU Council Directive 2011/16 on cross-border tax agreements, sometimes known as DAC6, has been in effect. Transparency and equity in taxation are goals of DAC6.

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Third Countries

In accordance with information-sharing agreements, Member States may also divulge information to tax authorities in third parties.

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Cross-border Arrangement

The automated information interchange between the tax authorities of the EU Member States does not seem to be restricted to those tax authorities.

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Close liaison

It will be crucial for taxpayers and other consultants to communicate clearly and on time.

DAC6 Features

The directive's list of "hallmarks" that display specific traits or elements of a cross-border arrangement defines the reporting duty. Hallmarks are categorized as:

Generic Hallmarks

Generic hallmarks related to the primary benefit test

Specific Hallmarks

Specific hallmarks related to the primary benefit test

Transfer Pricing

Specific Hallmarks of transfer pricing


How can PHG Help?

Tax, people, process, data, and technology professionals are all on our team. By combining these various skill sets, we are able to assist customers in understanding DAC6 and the larger context of tax policy, as well as in implementing efficient controls and procedures to guarantee that all reportable cross-border arrangements are promptly recognised and managed.

What will be the result of failure to comply with DAC6?

Failure to abide by DAC6 might result in serious legal repercussions in EU nations as well as reputational risks for businesses, people, and intermediaries. Businesses must therefore comprehend the significance and ramifications of the directive.

Who is required to report under DAC6?

A reportable cross-border arrangement must be designed, marketed, organised, made available for execution, or managed as it is being implemented, and the directive places the reporting burden on intermediaries based in the EU (or provides aid, assistance, or advice)