DAC 6: Country by Country analysis

11 February 2020
With the European Union target for all Member States to have passed appropriate legislation to enforce the Directive on Administrative Cooperation in the field of Taxation (DAC6) by 31 December 2019 having passed, we briefly look at what the state of play is across Europe as we move closer towards the 31 August 2020 deadline.

Legislation passed

Legislation has been passed in Austria, Belgium, Bulgaria, Croatia, Denmark, Estonia, Finland, France, Germany, Hungary, Ireland, Lithuania, Malta, The Netherlands, Poland, Slovakia, Slovenia, United Kingdom.

Points of interest:

  • Whilst legislation has been passed in these jurisdictions, very few have issued finalised guidance and released finalised details of the reporting portals as of yet, so uncertainty still remains, despite the ever-closer deadlines.
  • In Denmark there has been a narrowing of the legal privilege definition, therefore reducing the possibilities of lawyers being able to rely on the provision and will bring more arrangements into scope of the legislation.
  • In Germany, the legislation passed in closely in line with the EU Directive and did not include any provision to include Domestic arrangements as previously rumoured.  This option does remain a possibility but requires a separate piece of legislation to enforce.
  • Poland has diverged from the Directive with its commencement date of 1 January 2019, therefore reporting has already begun. Poland has also included Domestic arrangements within the legislation, bringing many more transactions into scope and increased the burden on Polish entities. 
  • In the United Kingdom, despite the likelihood of a Brexit decision being finalised, the government passed legislation in early 2020 and is committed, at this time, to fulfilling the requirement to exchange the relevant information with the other EU member states, despite growing concern of the impact on business.
DAC6 Europe_Revised_V2


Draft legislation published

The following Countries have issued draft legislation for consultation but have not yet put it into law: Cyprus, the Czech Republic, Luxembourg, Portugal, Romania, Spain, Sweden.

Whilst this legislation remains in draft, there is a possibility that it could be amended before being placed into law, though there is unlikely to be any significant changes.  There is also no indication currently that the proposed timelines for reporting, contained with the Directive, will be delayed, therefore work should continue to be prepared as much as possible.

No legislation published

Greece and Latvia have yet to publish any documentation concerning their legislation though are committed to follow the EU Directive.

The Channel Islands

The Channel Islands have recently agreed to enact the OECD version of the Mandatory Disclosure Rules in respect of the Common Reporting Standard anti-avoidance provisions and have so far issued consultation papers to industry for comment. 

Are you ready for DAC6?

With deadlines approaching fast, and the need for businesses to prepare as much as they can to meet reporting requirements if necessary, it is vital that they keep up to date with requirements in every jurisdiction in which they operate.  

How can Vistra help?

Vistra, as a subject matter expert in governance, tax compliance and regulation, is constantly mindful of statutory and regulatory obligations that affect our clients and is fully committed to helping them to stay compliant. 

If you have any questions about DAC6 or to find out how we can help you stay compliant, please contact one of the below:





Eric Hendrickx
Didier Westen

+32 3 226 08 83
+32 3 226 08 83


Laura Michael

+357 2 527 2717


Nico Dorenkamp
Lydia Roeth

+49 89 139 900-26 
+49 221 800 508-220


Sean Hernon

+353 6171 0120


Axel Motte
Nicolai Nielsen

+352 422 229 256
+352 422 229 525


Alistair Schembri

+356 2258 6426


Nicole van Bunge

+31 88 560 9755


Andrzej Pietrasik

+48 22 205 65 12


Claudia Vera
Daniela Salime Reyes
Ana Claramunt

+34 93 467 10 20 (ext 109)
+34 91 522 63 35 (ext 203)
+34 93 467 10 20 (ext 119)


Philipp Marzohl

+41 44 296 68 47


Martin Palmer
John Tay
Michael Thomas

+44 117 918 1321
+44 117 918 1306
+44 1534 504 514