The 31 December deadline for EU Member States to adopt implementing legislation for DAC 6 is fast approaching. Intermediaries and taxpayers must be ready for compliance.

By the end of 2019, each Member State of the European Union must enact domestic legislation to implement DAC 6, an EU Directive on Administrative Cooperation aimed at combating aggressive cross-border tax-planning structures. The Directive introduces an obligation on intermediaries with EU connections (such as lawyers, accountants, and tax advisers) - and, in some cases, on taxpayers with EU connections - to disclose reportable cross-border arrangements to relevant local tax authorities, which will subsequently exchange this information with other EU tax authorities. The language of the Directive is broad in scope, both in respect of what constitutes a reportable cross-border arrangement and who is considered to be an intermediary. In certain cases, ordinary course commercial transactions with no particular tax objective may be covered by the regime.