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By Romain TIFFON and Marie BENTLEY, ATOZ Tax Advisers *
On 13 March 2018, the EU Finance Ministers reached a political agreement on the Proposal for a Council Directive amending Directive 2011/16/EU (“DAC”) as regards mandatory automatic exchange of information in the field of taxation in relation to reportable cross-border arrangements (the “Directive Proposal”).
This article provides an overview of:
(i) what type of arrangement will need to be reported;
(ii) what the Hallmarks used to determine the reportable cross-border arrangements under the Direc-tive Proposal are;
(iii) which information will be reported;
(iv) who will be subject to the new reporting duties;
(v) when the reporting will have to be...
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