Regulations · Regulation explained
DAC6 — reportable cross-border arrangements
DAC6 makes advisers the reporting sensors of aggressive cross-border tax planning. If an arrangement crosses a border and shows one of the Annex IV hallmarks, someone must report it — and the 30-day clock starts earlier than most people think.
The requirements, article by article
30 days, from the earliest trigger
The report is due within 30 days of the arrangement being made available, being ready for implementation, or the first step being implemented — whichever comes first.
In Sceau — Deadline tracking counts from the earliest trigger date on the arrangement record.
Know the hallmarks
Hallmarks A–E define what is reportable, several only in combination with the main-benefit test — from confidentiality clauses to transfer-pricing patterns.
In Sceau — The hallmark assessment walks each category with the main-benefit test built in.
Privilege shifts the duty, it does not end it
Where legal professional privilege exempts the intermediary, they must notify other intermediaries or the taxpayer, on whom the duty then falls.
In Sceau — The privilege workflow records the notification and shifts the deadline to the right party.
Report the full data set
The report identifies intermediaries and taxpayers, the hallmarks, a summary of the arrangement, its value, and the member states concerned.
In Sceau — The workpaper assembles the schema-complete filing from the assessment.
Marketable arrangements need updates
Marketable arrangements require periodic update reports listing new users.
In Sceau — Update cycles are scheduled on the arrangement with reminders.
This page is a plain-language orientation, not legal advice. Article numbering follows the instrument as published in the Official Journal; where implementing technical standards are still in draft, we say so. The legal text always prevails.
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