Legal & Tax Alerts

New deadlines for reporting cross-border tax arrangements (DAC6)

The deadlines for reporting cross-border tax arrangements[1] have been recently prolonged[2], as follows:

The intermediaries or the relevant taxpayers, as the case may be, should report until February 28, 2021, the information on the reportable cross-border arrangements for which the first step in the implementation process was performed between June 25, 2018 and June 30, 2020.

The 30-day period within which the intermediaries or the relevant taxpayers, as the case may be, were required to report information on reportable cross-border arrangements is extended and begins as of January 1, 2021, for cross-border arrangements carried-out between July 1, 2020 and December 31, 2020.

In the case of marketable arrangements, the first updated report is made by the intermediary until April 30, 2021.

The National Agency for Fiscal Administration communicates, through the automatic exchange, the first information by April 30, 2021.

 

[1] The necessity to report cross-border arrangements was provided by Council Directive (EU) 2018/822 amending Directive 2011/16/EU as regards the mandatory automatic exchange of information in the field of taxation in relation to reportable cross-border arrangements (“DAC6”), transposed by Government Ordinance no. 5/2020 for amendment and completion of Law no. 207/2015 regarding the Fiscal Procedure Code.

[2] By Government Emergency Ordinance no. 107/2020 regarding article II of Government Ordinance no. 5/2020 for amendment and completion of Law no. 207/2015 regarding the Fiscal Procedure Code and prolongation of certain deadlines, published in Official Gazette, Part I, no. 579 of July 1, 2020.

Cookie Settings