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

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Last updated June 30, 2020.

On May 25, 2018, the Council of the European Union formally adopted Council Directive (EU) 2018/822 of 25 May 2018 amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation in relation to reportable cross-border arrangements.

TP News_DAC6_EU Country Implementation ReportThe Directive (commonly known as DAC6) requires member states to implement rules requiring intermediaries (such as lawyers, law firms, accountants, auditors, banks etc.) and relevant taxpayers (i.e. where there is no intermediary or where professional secrecy privilege applies) to report information on certain cross-border tax arrangements to the tax authority.

Those tax arrangements must be reported which indicate a potential risk of tax avoidance. This is understood by reference to five Categories of hallmarks, some of which need to satisfy the “main benefit test”.

The Directive takes effect from July 2020. Member states were required to transpose the provisions of the Directive into their domestic tax law by December 31, 2019.

DAC6 Country Implementation

Countries highlighted in red are yet to gazette final legislation on DAC6.

As on June 30, 2020, six member states have issued draft legislation on DAC6 but are yet to finalize the same.

COVID-19 deferral: To address the severe disruptions created by the COVID-19 pandemic, the EU will allow more time to comply with rules on cross-border information reporting.

The EU Council has adopted an amendment to allow member states an option to defer by up to 6 months the time limits for the filing and exchange of cross-border arrangements. Some member states have already announced a six-month extension. The extensions granted by individual member states are noted below. This page will be continuously updated to reflect latest developments in this regard. 

Click here for an overview of the DAC6 Country Implementation Report 2020.

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.

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 Explanatory Notes

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

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. 
Czech Republic On August 20, 2019, the Finance Ministry issued a revised draft Law to require taxpayers/ intermediaries to report information on certain tax arrangements. Domestic arrangements are not included. No new hallmarks have been specified.

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

COVID-19: no extension applies

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

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 In June 2020, the Finance Ministry presented before the Cabinet a draft Bill to require taxpayers/ intermediaries to report information on certain tax arrangements.
Hungary On July 23, 2019, Hungary gazetted law to require taxpayers/ intermediaries to report information on certain tax arrangements.

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.

COVID-19: 6-month extension applies

Italy In 2018, the Ministry of Finance published for public comments a consultation document on requiring taxpayers/intermediaries to report information on certain tax arrangements. 
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.

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.

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

COVID-19: 6-month extension applies

Portugal On June 19, 2020, the Portuguese Government passed Law to require taxpayers/ intermediaries to report information on certain tax arrangements. 
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.
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 May 12, 2020, Spain’s Council of Ministers approved draft Law to require taxpayers/intermediaries to report information on certain tax arrangements. Domestic arrangements are not included. No new hallmarks have been specified. 
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