DAC 6 is a new regime under which intermediaries and/or taxpayers must report to an EU tax authority information about cross-border arrangements with a view to the information being exchanged with other EU tax authorities.

The new regime will go fully live on 1 July 2020, but it will be back-dated to include cross-border arrangements in which the first step was taken on or after 25 June 2018 (“the two year look back period”).

Many EU countries have now implemented the Directive (Directive 2018/822) into their local law and are in the process of issuing guidance, but a lack of clarity on the scope of the rules remains.