DAC6 arrangement register: hallmarks, deadlines and filing evidence
How tax intermediaries and relevant taxpayers can turn DAC6 from a hallmark checklist into a controlled reporting workflow.
Executive summary
DAC6 requires arrangement-level analysis, not only file notes.Hallmarks, MBT, privilege, role and deadlines must be recorded.Sceau prepares and evidences; the office signs off and files.DAC6 is not just a question of whether a hallmark appears. The office needs to understand whether there is a cross-border arrangement, who has the reporting role, whether privilege affects the route, which hallmark applies, whether the main-benefit test matters and when the deadline runs.
A serious DAC6 workflow therefore needs an arrangement register, parties, timelines, evidence, hallmark analysis, sign-off and export preparation, not a loose note in the tax file.
Sceau’s position remains prepare-and-evidence: the platform structures the analysis and can prepare Belgian XML where configured, while the office keeps the legal conclusion and official filing responsibility.
Who this applies to
This guide is for tax intermediaries, relevant taxpayers and professional offices that assess cross-border arrangements under DAC6.
- Tax advisors and accountants
- Lawyers handling tax-structured mandates
- Intermediaries with privilege questions
- Groups preparing Belgian DAC6 XML
- Offices needing proof of non-reportable conclusions
Legal and supervisory context
DAC6 introduced mandatory disclosure rules for certain cross-border arrangements. The workflow must identify the arrangement, parties, hallmarks, reporting role, deadlines and whether privilege changes the reporting path.
A checklist alone is weak because deadlines and reporting responsibility depend on facts, timing and role.
What the office must actually do
The office should turn the obligation into a repeatable workflow with named owners, deadlines, evidence and reviewable decisions.
- Create an arrangement record.
- Add parties and jurisdictions.
- Assess cross-border gateway and taxes.
- Evaluate hallmarks A to E and MBT where relevant.
- Record privilege and reporting responsibility.
- Prepare memo or XML and filing evidence.
What good evidence looks like
The register should show the analysis, sign-off, deadline calculation, prepared export and proof of filing or non-reportable conclusion.
Common mistakes supervisors find
- Assessing DAC6 only at client-file level.
- Ignoring privilege and reporting-position evidence.
- Missing deadline triggers.
- Preparing XML without mandatory fields or sign-off.
Practical checklist
- Open arrangement.
- Add parties.
- Run hallmark assessment.
- Review MBT and privilege.
- Calculate deadline.
- Sign off conclusion.
- Prepare export or record non-reportable memo.
- Maintains a DAC6 arrangement register.
- Runs guided hallmark assessments.
- Prepares Belgian XML when schema is configured.
- Stores conclusion memos and filing acknowledgements.
FAQ
Is every tax planning file reportable?
No. DAC6 depends on cross-border scope, hallmarks and other conditions. The conclusion should be documented.
Does Sceau file DAC6 directly?
The platform prepares and evidences; official filing remains with the office or responsible taxpayer/intermediary.
What if another intermediary filed?
Record proof of other filing or exemption in the arrangement evidence.
Official references
From knowledge to compliance
Reading is a start. Sceau turns these obligations into a workflow that runs itself and proves itself.
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