DAC 6 – Mandatory disclosure regime for cross-border tax arrangements
The DAC 6 module on AMANA’s tax portal
All EU member states must transpose the EU’s new mandatory disclosure regime for cross-border tax (DAC 6) into national law by 31.12.2019. Taxpayers and intermediaries affected by the disclosure requirement are obliged to file their audits and reports within 30 days. Furthermore, the directive provides an initial one-off reporting deadline of 01.07.2020 and from then onwards a 30-day rolling window for reporting new arrangements will apply. Several EU member states have already published draft legislation.
The disclosure requirement applies to all direct taxes, notably corporate and trade tax, but also taxation of inheritance and gifts.
For the automatic exchange of information between member states the directive foresees the European Union’s common communication network – or CCN. In Germany information will be reported to the BZST (the German Federal Central Tax Office).
DAC 6 requirements present companies with several challenges:
- Setting up internal processes to record, document, control and analyze reportable arrangements
- Coordination of a procedure for the mandatory disclosure regime with consultants, but also between affected group companies
- Clear allocation of responsibilities
- Mapping and monitoring of regulations specific to certain EU member states
- Full and traceable documentation showing that all reporting obligations have been met
The AMANA DAC 6 module
As part of the web-based AMANA tax portal, the DAC 6 module supports our solution all the way through: from data capture to analysis and finally documentation / disclosure: 1:
- Compliance monitoring – status of disclosures
- Coordination of reporting between group companies
- Monitoring of processes using milestones and dashboards
- Calendar-based deadline monitoring
- Safeguarding the four-eyes principle
- Flexible questionnaires that the company or consultants can adapt for each country (upload per period and country)
- Questionnaires based on interactive decision trees can assist with the identification, recording and evaluation of reportable arrangements
- Documentation in the form of file attachments
- Wide-ranging roles and authorizations
- Dashboards and reports
- Straightforward maintenance of master data
The AMANA DAC 6 module was developed as a standard software in collaboration with our implementation partners specifically for the MDR process and covers the regime’s core disclosure obligations.
Our implementation partners will work out a tailored compliance process with your company for the disclosure of your reportable tax arrangements:
- Devising flexible questionnaires and adapting these to the requirements of individual EU member states
- Assistance with the identification, recording, evaluation and display of reportable arrangements
- Training staff
- Internal control and checkpoints
1 Since disclosure particulars are currently awaiting finalization from the regulatory authorities, no statement regarding implementation can yet be provided. At present draft legislation for disclosure has already been published in Germany and certain other member states.