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ARTICLE · 27 NOVEMBER 2020

Always More Transparency In The EU: DAC6 And Transfer Pricing

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The European Union passed a sixth version of its Directive on Administrative Cooperation in the Field of Taxation, known as "DAC 6" (Directive (EU) 2018/82 2)...

United KingdomTax
Astrid Pieron
Astrid Pieron
James Hill
James Hill
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The European Union passed a sixth version of its Directive on Administrative Cooperation in the Field of Taxation, known as “DAC 6” (Directive (EU) 2018/82 2), on 25 May 2018. DAC 6 introduces reporting requirements for professional intermediaries (and under certain circumstances tax payers) relating to their involvement in a wide range of cross-border arrangements and transactions featuring “hallmarks” of tax planning concerning one or more EU Member States or the UK. These are referred to in DAC 6 as “reportable cross-border arrangements“. Specific hallmarks relate to transfer pricing (category E) and they do apply without main benefit test.

Failure to comply with DAC 6 could imply significant penalties under domestic legislations of the EU member states (and the UK) as well as reputational risks for not only intermediaries ( law firms, accounting firms , banks …) but also for businesses and individuals.

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