DAC6 mandatory disclosure: how to prepare

DAC6 timeline

Tackling tax avoidance and evasion is key to ensure that everyone pays their fair share of tax.

Working with the OECD, the EU Commission and other EU member states, the UK government has introduced the Directive on Administrative Cooperation (DAC6) which aims to identify potentially aggressive tax arrangements by further increasing reporting transparency.

What is DAC6?

DAC6 introduces a requirement for tax intermediaries and advisers to provide tax authorities with details of certain international tax planning arrangements. Where the arrangements fall within certain 'hallmarks' mentioned in the directive and in circumstances where the intended benefit of the arrangement is a tax advantage.

In certain instances the obligation to report falls on the taxpayer and information reported will be shared between tax authorities. There are no de-minimis limits and penalties for failures can be significant, with local country penalties in the range of several million Euros.

EU member states were required to incorporate DAC6 into their domestic law by 31 December 2019. Under the Directive, reporting starts after July 2020 for arrangements dating from 25 June 2018. On 8 May 2020 the EU Commission proposed a delay of up to three months in the commencement of reporting, due to the disruption caused by coronavirus.

RSM can help you navigate DAC6 and prepare you for the upcoming changes. Download our guide to understand the reporting requirements and how international transactions and arrangements must be reported to tax authorities in future. 

      Download our DAC6 guide  

Recent news

25 June - UK Government announces a six-month deferral of the first DAC6 reporting deadlines. This is to provide additional time for taxpayers and their intermediaries, dealing with the impact the coronavirus pandemic to comply with their obligations. This is in line with the approaches announced by a number of other implementing jurisdictions.

24 June - The EU ratified an amendment to the Directive (DAC6), allowing EU member states an option to defer the time limits for the filing and exchange of the relevant information on reportable arrangements by up to six months in light of the severe disruption caused by the coronavirus outbreak, subject to local country implementation. 

1 June - We are now past the end of May deadline and there is no news yet from the EU Commission on the adoption of the proposed directive to extend the DAC6 reporting deadline.

29 May - HMRC issues xml reporting schema for DAC6 – details of the manual data entry facility still awaited.

11 May - EU Commission proposes postponement of date for the first exchange of information on reportable cross-border arrangements from 31 October 2020 to 31 January 2021. The reporting deadline for arrangements between 15 June 2018 and 30 June 2020 is delayed from 31 August to 30 November 2020. The commencement of 30 day reporting to be delayed by up to three months.


Insight4GRC and DAC6

Helping organisations with the mandatory reporting of international tax planning.

The Insight4GRC platform enables organisations to gain visibility and take control of their tax risk landscape. This suite of solutions comprises of three modules which can be deployed with flexibility to coordinate intermediaries, ensure internal compliance and track reporting obligations.

      Download our brochure  

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Are you ready for DAC6?

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Discover how our Insight4GRC software can help you to prepare for DAC6. 

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Watch our webinar with RSM leaders from Europe and the United States as they provide visibility into the framework and its potential impact.

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