Getting through to a taxpayer via its tax advisor is no new policy. It first started 20 years ago in the US and moved on to the UK placing intermediaries under an obligation to report the so-called tax avoidance schemes. The EU is now joining the club with an
unpredictable experiment enforcing common minimal standards in reporting ”potentially aggressive tax arrangements”. An experiment which is unpredictable primarily for multinational groups of enterprises to be faced with interpretations of 27 (28, because, despite BREXIT, UK seems to be in this game) jurisdictions which are still different from each other in terms of direct taxes.

In preparing the unavoidable moment of DAC6 becoming enforceable, this TPS paper sets out to bring together some of the myriads of questions and ambiguities, and some of the few certainties related to the new obligations, based on materials issued so far by the European Commission and other Member States.

Please find here the entire article.

The original version (RO) appeared in the Romanian Tax Advisers magazine, in July 2019