EU Country Implementation Table – Directive 2018/822 (DAC6)

The EU Council Directive (EU) 2018/822 of 25 May 2018 (commonly known as DAC6) requires member states to implement rules requiring intermediaries and relevant taxpayers to report information on certain cross-border tax arrangements to the tax authority. The Directive took effect from July 2020. 

TP News_DAC6_EU Country Implementation Report

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As on January 5, 2021, 26 EU member states and the UK have adopted legislation transposing the Directive into their domestic tax law. Cyprus has issued draft legislation on DAC6 but is yet to finalize the same.

We at TP News have prepared a EU COUNTRY IMPLEMENTATION REPORT ON DAC6 – 2021, covering the DAC6 legislations for all EU member states.

The Report covers:

  • Information on implementation of the DAC6 reporting requirement on a country-by-country basis
  • Guidance issued by individuals member states on important concepts, including the main benefit test, tax advantage and arrangement
  • Clarifications issued by individual member states on different categories of hallmarks
  • Information on penalties for non-compliance for individual member states
  • Information on the reporting format for individual member states; and
  • Links to the domestic legislations and guidance.

Please contact us at editor@transferpricingnews.com if you would like to purchase a copy of the Report.


Below is a table setting out implementation status of the Directive in each EU Member State. The table is regularly updated to reflect changes and developments.

© TP News. 2020-21. All rights reserved. Last updated January 5, 2021.

Austria On October 22, 2019, the Government gazetted Law to require taxpayers/intermediaries to report information on certain tax arrangements. Domestic arrangements are not included. No new hallmarks have been specified.

See Guidance

Deferral applies until October 31, 2020

Belgium On December 30, 2019, the Belgian Government gazetted Law to require taxpayers/ intermediaries to report information on certain tax arrangements.

See Guidance

COVID-19: 6-month extension applies

Bulgaria On December 31, 2019, the Bulgarian Government gazetted Law to require taxpayers/ intermediaries to report information on certain tax arrangements. 

COVID-19: 6-month extension applies

Croatia On December 11, 2019, the Croatian Government gazetted Law to require taxpayers/ intermediaries to report information on certain tax arrangements.

See Guidance

COVID-19: 6-month extension applies

Cyprus On October 22, 2019, the Finance Ministry issued draft Law to require taxpayers/ intermediaries to report information on certain tax arrangements. 

See Guidance

See further Guidance

COVID-19: 6-month extension applies

Czech Republic On August 14, 2020, the Czech Government gazetted Law to require taxpayers/ intermediaries to report information on certain tax arrangements.

See Guidance

COVID-19: 6-month extension applies

Denmark On December 28, 2019, the Danish Government gazetted Law to introduce rules requiring taxpayers/intermediaries to report information on certain tax arrangements.

See Guidance

COVID-19: 6-month extension applies

Estonia On December 21, 2019, the Estonian Government gazetted Law to require taxpayers/ intermediaries to report information on certain tax arrangements.

COVID-19: 6-month extension applies

Finland On December 30, 2019, Finland’s President signed Law to require taxpayers/ intermediaries to report information on certain tax arrangements. 

See Guidance

France On October 22, 2019, the Government gazetted Law to require taxpayers/intermediaries to report information on certain tax arrangements. Domestic arrangements are not included. No new hallmarks have been specified.

See Guidance

See Further Guidance

COVID-19: 6-month extension applies

Germany On December 30, 2019, the German Government gazetted Law to require taxpayers/ intermediaries to report information on certain tax arrangements.

See Guidance

Greece On July 31, 2020, the Government gazetted Law to require taxpayers/ intermediaries to report information on certain tax arrangements.

See Explanatory Memorandum

COVID-19: 6-month extension applies

Hungary On July 23, 2019, Hungary gazetted law to require taxpayers/ intermediaries to report information on certain tax arrangements.

See Guidance

COVID-19: 6-month extension applies

Ireland On January 3, 2020, the Government gazetted Finance Act, 2019, which contains provisions to require taxpayers/intermediaries to report information on certain tax arrangements.

See Guidance

COVID-19: 6-month extension applies

Italy On July 30, 2020, the Government published Law to requiring taxpayers/intermediaries to report information on certain tax arrangements. 

See Guidance

Draft Circular

COVID-19: 6-month extension applies

Latvia On March 5, 2020, the Government adopted law requiring taxpayers/intermediaries to report information on certain tax arrangements.

COVID-19: 6-month extension applies

Lithuania In July 2019, the Government adopted law requiring taxpayers/intermediaries to report information on certain tax arrangements.

See Guidance

COVID-19: 6-month extension applies

Luxembourg On March 26, 2020, the Government gazetted Law requiring taxpayers/intermediaries to report information on certain tax arrangements. Domestic arrangements are not included. No new hallmarks have been specified.

See English translation of the DAC6 legislation

See Guidance

COVID-19: 6-month extension applies

Malta On December 17, 2019, the Maltese Government gazetted Law to require taxpayers/ intermediaries to report information on certain tax arrangements.

See Guidance

See Guidance

COVID-19: 6-month extension applies

Netherlands On December 27, 2019, the Dutch Government gazetted Law to require taxpayers/ intermediaries to report information on certain tax arrangements.

See FAQs

See FAQs in English

See Guidance

COVID-19: 6-month extension applies

Poland Mandatory disclosure rules are effective from January 1, 2019.

See Explanatory Notes

See FAQs

COVID-19: 6-month extension applies

Portugal On July 21, 2020, the Portuguese Government gazetted Law to require taxpayers/ intermediaries to report information on certain tax arrangements. 

Form 58

COVID-19: 6-month extension applies

Romania On January 31, 2020, the Romanian Government gazetted Law to require taxpayers/ intermediaries to report information on certain tax arrangements.

COVID-19: 6-month extension applies

Slovakia On October 14, 2019, the Government gazetted Law to require taxpayers/ intermediaries to report information on certain tax arrangements. Domestic arrangements are not included. No new hallmarks have been specified.

See Explanatory Memorandum

COVID-19: 6-month extension applies

Slovenia Mandatory disclosure rules were published in the Official Gazette of June 7, 2019 and entered into force on June 22, 2019. Domestic arrangements are not included. No new hallmarks have been specified.

See Guidance (downloadable link)

COVID-19: 6-month extension applies

Spain On December 30, 2020, Spain gazetted Law to require taxpayers/intermediaries to report information on certain tax arrangements.
Sweden On June 5, 2020, the Swedish Government gazetted Law to require taxpayers/ intermediaries to report information on certain tax arrangements.

See Guidance

COVID-19: 6-month extension applies

United Kingdom On January 13, 2020, Regulations requiring taxpayers/ intermediaries to report information on certain tax arrangements were laid before Parliament.

See Guidance

COVID-19: 6-month extension applies