At a time when lengthy books are being written on the Sixth Directive on Administrative Co-operation in Tax Matters (DAC6), it is a daunting task to summarise the key elements of DAC6. However, with an eye on 1 January 2021 when the clock starts ticking for the various deadlines for the initial set of reporting obligations, there are some material elements that deserve particular focus. This article examines those elements in the context of the principal objective of DAC6, namely to require a wide range of intermediaries to provide tax authorities with early warning of arrangements that involve aggressive tax planning so that they can take the necessary action to examine those arrangements under existing tax rules and to amend the tax rules as appropriate to prevent their further use.Download the PDF to read more.
