Cross-border transaction reporting delay under DAC 6 is welcome

Published by Andrew Wallis on 12 May 2020

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Last updated 12 May 2020

The European Commission has proposed a three-month delay to the implementation of the DAC6 directive that mandates cross-border transaction reporting, due to the Coronavirus.

Following a considerable amount of lobbying from businesses and professional bodies across the EU, many companies will welcome the proposed delay to certain deadlines.

However, companies should not sit on their laurels as the proposed delay:

  • will need to be legislated by Member States;
  • is only for three months; and
  • any reportable transactions that arise during the deferral period will still need to be reported by the end of the deferral period.

The proposed revised deadlines are therefore as follows:

Date of transactionOriginal filing dateProposed deferred filing date
Transactions implement between 25 June 2018 and 30 June 202031 August 202030 November 2020
Transactions between 1 July 2020 and 30 September 2020Within 30 days of transaction or date made available for implementation30 October 2020 (30 day period commences on 1 October)
Transactions from 1 October 2020Within 30 days of transaction or date made available for implementationWithin 30 days of transaction or date made available for implementation

Our recommendation is that wherever possible companies should continue to try and put processes in place to identify, evaluate and record transactions according to the original timelines given that all transactions will ultimately need to be reported.

For more details or assistance please get in touch.

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