Are you ready to monitor cross-border tax arrangements? You have to from 25 June 2018 onwards!

Bruno Hollenstein Partner and Leader Connected Compliance, PwC Switzerland 06 Jun 2018

On 5 June 2018, the Official Journal of the European Union published the Directive regarding mandatory exchange of information in relation to reportable cross border arrangements (“DAC6”). This is of special interest as the publication in the Official Journal means that intermediaries and taxpayers must monitor relevant cross-border arrangements the first step of which was implemented between the date of entry into force (which is now confirmed as 25 June 2018) and the date of application of this Directive (1 July 2020). 

What does this mean for your business?

Intermediaries (which includes tax advisors, lawyers, and service providers) and relevant taxpayers, as appropriate, shall file information on any of those cross-border arrangements which are reportable by 31 August 2020. It is important therefore for taxpayers and intermediaries to start to monitor arrangements which may fall within these rules now.

In addition to the reporting of relevant arrangements mentioned above, if a reportable cross border arrangement is (i) made available for, or (ii) is ready for implementation, or (iii) if the first step is implemented on 1 July 2020 or later, such an arrangement must be reported within 30 days of the earliest date of one of those factors being fulfilled.

What's next?

The Member States of the EU will have until 31 December 2019 to implement the provisions of the directive into local law and regulations. Although this is an EU directive, its impact will be felt in Switzerland (e.g. for Swiss groups with EU subsidiaries, Swiss intermediaries advising EU clients etc.). 

Don’t be caught out by DAC6

Read the Official Journal of the European Union here.

Get more information and stay up to date on DAC6 by visiting our dedicated website.

Summary
  • The EU have published the final version of DAC6.
  • This means that 25 June 2018 is the starting date for taxpayers and intermediaries to monitor possible reportable arrangements.
  • Member States of the EU have until 31 December 2019 to implement the directive into local law.

Contact Us

Monica Cohen-Dumani

International Tax Services, EMEA ITS Leader, Geneva, PwC Switzerland

+41 58 792 97 18

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Bruno Hollenstein

Partner and Leader Connected Compliance, PwC Switzerland

+41 58 792 43 72

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