Reference : DAC6 and the Challenges Arising from Its Disclosure Obligation
Scientific journals : Article
Law, criminology & political science : Tax law
Law / European Law
DAC6 and the Challenges Arising from Its Disclosure Obligation
Bianco, Arthur mailto [University of Luxembourg > Faculty of Law, Economics and Finance (FDEF) > Department of Law (DL) >]
EC Tax Review
Kluwer Law International
Yes (verified by ORBilu)
[en] Directive 2018/822 (‘DAC6’) aims at ensuring the exchange of information between Member States of potentially tax-aggressive arrangements. To do so, the European legislator has entrusted intermediaries across the European Union with the task of gathering and reporting a number of potentially aggressive tax arrangements to improve tax transparency and stifle tax avoidance. Unfortunately, a closer analysis of the text has revealed multiple issues that may threaten the well-functioning of the system and could impede the action of the intermediaries. From missing definitions and a lack of guidance to new concepts in dire need of proper interpretation, intermediaries are left with a daunting task to tackle. Risks of delays and over-disclosure, arising from the inconsistencies and uncertainties left by the text of the instrument, may not only undermine the effectiveness of the reporting obligation, but also that of the rest of the system altogether.

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