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DAC 6

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In 2020, Directive 2018/822/EU (the so-called DAC 6) was implemented into the Czech legal system (specifically through the International Cooperation in Tax Administration Act). This Directive introduces a new reporting obligation in relation to cross-border arrangements that features at least one of the hallmarks. The notification obligation applies not only to new cross-border arrangements, but also to historic cross-border arrangements implemented after the operative date of 25 June 2018.

Taxable entities are consequently obliged to verify whether they are a party to such cross-border arrangements and whether such arrangements meet the requirements for notification to the tax authorities.

Due to the general and ambiguous regulation of this reporting obligation, and the fact that non-compliance with the obligation is subject to legal penalties stipulated, we offer our clients assistance with the initial assessment of whether the reporting obligation under DAC 6 applies to them at all. We will provide them with basic guidance on how to proceed with the screening of cross-border transactions and then work with them to identify the transactions that are subject to the reporting obligation. If necessary, we will also prepare a complete and detailed analysis of the cross-border transactions and prepare the required notification to the tax authorities. Due to the worldwide presence of the Rödl & Partner Group, we are also able to provide DAC 6 analysis at our foreign offices.

Contact

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Mgr. Kateřina Jordanovová, LL.M.

Attorney-at-Law (Czechia), Tax Advisor (Czechia)

Senior Associate

+420 236 163 111

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