1. Introduction
Put in brief, the Mandatory Disclosure Directive1
(the Directive) imposes the obligation on
intermediaries and – under certain circumstances –
relevant taxpayers to report certain cross-border arrangements to
the tax authorities.
The Dutch legislation implementing the Directive (the
Dutch DAC6 legislation) entered, as required, into
effect on 1 July 2020, having retroactive effect until 25 June
2018.
This issue of Quoted includes a detailed description of the
Dutch DAC6 legislation. Paragraph 2 contains an executive summary
of this Quoted. Paragraph 3 provides for a short overview of the
background of the Dutch DAC6 legislation. Paragraph 4 focuses on
the (interpretation of the) most relevant provisions and
definitions of the Dutch DAC6 legislation. In paragraph 5, the
potential impact for taxpayers is addressed followed by some
guidance on how taxpayers can be in control of the potential impact
of the Dutch DAC6 legislation.
