Enhancement of EU Directive on Administrative Cooperation ("DAC 6") - new reporting obligation as of 2020 for cross-border tax planning arrangements
by Gunther Manske
With the "DAC 6" directive of the EU, which came into force on 25.06.2018, there will be a new reporting obligation for (inter alia) banks and financial service providers from 2020 onwards, insofar as these are involved in any way in the field of such cross-border tax arrangements. In particular, it should be noted that under the reportable arrangements in the meaning of the directive, a number of “normal” banking transactions may also be affected that are not yet covered by the annual Automatic Exchange of Information on Financial Accounts ("AEI"). Even if the respective national implementations of the DAC 6 directive are still pending and a number of details are still unclear, banks and financial service providers should already be actively deal with this topic, since this already covers all respective arrangements implemented since 25.06.2018 and their future reporting.