DAC6 (Directive on Administrative Cooperation, sixth amendment) is an EU directive requiring the disclosure of cross-border tax arrangements that could be used to avoid tax. It applies to intermediaries (such as tax advisors, accountants, and lawyers) and, in some cases, taxpayers themselves.
DAC6 was introduced to enhance transparency and tackle aggressive tax planning across EU member states. By mandating the reporting of potentially harmful arrangements, tax authorities can better detect and respond to risks to their tax bases.
Organizations that operate across borders—especially those with complex structures or transactions—must be aware of DAC6 to stay compliant and avoid potential penalties.
DAC6 requires certain intermediaries—such as tax advisors, accountants, lawyers, or banks—to report cross-border arrangements that meet specific risk indicators, known as hallmarks, to their national tax authorities. In some cases, the obligation may shift to the taxpayer.
By making these arrangements visible to authorities, DAC6 enables tax administrations across the EU to share data, coordinate enforcement, and respond faster to risks to their tax bases.
Failure to comply with DAC6 can lead to financial penalties and reputational damage, making it essential for organizations operating internationally to stay on top of their disclosure obligations.
A cross-border arrangement must be reported if it meets certain hallmarks set out in the directive. These hallmarks cover a range of characteristics, including:
A reportable cross-border arrangement (RCBA) is one that involves more than one jurisdiction and meets at least one of five hallmark categories listed in Annex IV of the directive:
Not all hallmarks require a tax advantage to be present, which means some arrangements must be reported even if they are not considered aggressive tax planning.
In most cases, intermediaries—such as legal, financial, or tax advisors—are responsible for reporting. However, if no intermediary is involved (or bound by legal professional privilege), the obligation may fall to the taxpayer.
DAC6 includes a 30-day window for reporting. Intermediaries or taxpayers must disclose a reportable arrangement within:
DAC6 compliance can be complex, especially with tight reporting timelines (often within 30 days of the arrangement being made available). Impero helps streamline the process by:
Staying compliant with DAC6 doesn’t need to be a manual, high-risk task. With Impero, you gain visibility, control, and confidence over your tax governance processes.
👉 Get in touch to see how we can help your team stay ahead of regulatory requirements like DAC6.
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