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By Oliver R. HOOR Marie BENTLEY, ATOZ Tax Advisers*
On 24 June 2026, the Euro-pean Commission published a proposal to recast the Directive on administrative cooperation in taxation (“DAC”) (the “Recast Proposal”). The proposed changes mainly focus on DAC 6, which provides a mandatory disclosure regime for potentially aggressive cross-border tax planning schemes. This article provides an overview of the proposed changes and offers a critical assessment of whether they go far enough.
Since 2011, the DAC framework has grown considerably, expanding to encompass a variety of information exchange categories, including financial accounts (DAC2), tax rulings (DAC3), country-by-country reporting (DAC4),...
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