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Council Directive (EU) 2018/822 (DAC6) - Mandatory Disclosure of Reportable Cross-Border Tax Arrangements: Hallmark Categories A-E, 30-Day Reporting Window, Intermediary and Taxpayer Obligations, Main Benefit Test and Automatic Competent Authority Exchange

Intermediaries (advisers, banks, accountants) who design, market, organise, or implement cross-border arrangements with at least one hallmark indicating…

What Council Directive (EU) 2018/822 (DAC6) - Mandatory Disclosure of Reportable Cross-Border Tax Arrangements: Hallmark Categories A-E, 30-Day Reporting Window, Intermediary and Taxpayer Obligations, Main Benefit Test and Automatic Competent Authority Exchange requires

Intermediaries (advisers, banks, accountants) who design, market, organise, or implement cross-border arrangements with at least one hallmark indicating potential tax avoidance must report to their Member State competent authority within 30 days; hallmarks A-C require the Main Benefit Test (MBT) to be satisfied before reporting is triggered; hallmarks D (CRS circumvention) and E (transfer pricing) are reportable per se without MBT; taxpayers self-report where no intermediary exists or where intermediary claims legal privilege; Member States exchange reported information automatically via OECD Common Transmission Network on a quarterly basis.

Pillar: Tax & Transfer Pricing · Authority: European Union (Council) · Version: 1.0.1 · Last updated:

Primary source: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32018L0822

SHA-256 integrity: 47d4b3b8a543bc70e62199c611102984e7c931d73370712c91b256248adc192d

Primary Citations — 6 traced to source

  • {"citation":"Council Directive (EU) 2018/822, Article 8ab(1) - Intermediary reporting obligation: 30-day window from earliest trigger date","url":"https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32018L0822","year":2018}
  • {"citation":"Council Directive (EU) 2018/822, Annex IV, Part I - Main Benefit Test definition: main benefit or one of the main benefits is obtaining a tax advantage","url":"https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32018L0822","year":2018}

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