E.U. Directive on Mandatory Disclosure Rules/DAC6
DAC6 imposes mandatory reporting of cross-border arrangements, affecting at least one Member State, where the said arrangements fall within one of a number of specified “Hallmarks”. The use of the words, “affecting at least one Member State”, means that the reportability of arrangements under the Directive is not limited to cross-border transactions within the E.U; it also includes arrangements between entities in the E.U. and entities in non-E.U. jurisdictions (for instance, an arrangement/transaction between a Dutch company and an Indian/Brazilian company). The aim of the DAC6 Directive is to improve tax-transparency and tackle potentially aggressive (cross-border) tax-planning arrangements in order to protect the tax base of the E.U. Member States.
