DAC6 Reporting Overview
Last update date: 22 April 2021

Member StateStatusGuidance

Major
departures fromDAC6Austria

Taxpayer annual reporting
obligation

Primary reporting obligation for taxpayers and intermediaries

Reporting language

Reporting format

Filing mechanism

Pre-registration
required for DAC6filing

Signature / e-signing
required for filing

LPP exemption

Penalties

Annual reporting
obligation

Form of annual
reporting

Adopted

Official language or English(English is mandatory for certaininformation)Web-based form
Paper-based report (under certaincircumstances)

Direct data entry to tax
authority portal_Yes

Lawyers, tax advisors, auditors, notaries, financial
institutions

Up to €50,000 one-off fine per violation

No_Adopted

Official language and English(Mandatory)

Electronic / XML file

Upload to tax authority
portal*No_Lawyers, tax advisors, auditors, notaries,
accountants

Up to €50,000 one-off fineNo_Adopted

Official language (it isrecommended that the descriptionof the arrangement is written inEnglish)

Web-based form

Direct data entry to tax
authority portal

Yes(Disclosure ofinformation has to beenabled on the esignature)Yes

All professionals who have a legal obligation("consultants")

Up to 5,000 BGN (approx. €2,500) per violation,
doubled in case of repeated offense in the same
categoryYes

Tax return

Adopted

Official language and English(Mandatory)Web-based form

Direct data entry to tax
authority portal

Yes

Yes

Lawyers, tax advisors

Up to HRK 200,000 (approx. EUR 26,500) one-offfine

Yes

Web based form

AdoptedEnglishElectronic / XML file

Upload via governmental
portal Ariadne

YesNoLawyers / law firms practicing the profession oflawyer as per the Cap.2 of Advocates Law

Up to €20,000 one-off administrative fineNo_Adopted

Official language or English(translation to Czech may be laterrequested)

Electronic / XML file

Upload to tax authority
portalNoYes

Lawyers, tax advisors, auditors, notaries

Up to CZK 500,000 (approximately €20,000) one-off
fine per violation

No_Adopted

English(Certain information canadditionally be reported in locallanguage)

Web-based formDirect data entry to tax
authority portalYes

Yes

Lawyers (only for the information that wouldincriminate the taxpayer)

Up to DKK 400,000No_Adopted

Official language or English

Web-based form (XML file possiblity
will become available later)

Direct data entry to tax
authority portal*NoNolawyers, auditors (including tax advisors employedby audit firm)

Up to €3,300 one-off fine

No_Adopted



Official language or English(English recommended)

Electronic / XML file
Paper-based report (under certaincircumstances)Upload to tax authorityportal*NoYesLawyersUp to €15,000 per reportable arrangement

No_Adopted

Official language (but for certain
information the tax authorities
recommend to also report inEnglish)

Electronic / XML fileWeb-based form

Upload or direct data
entry to tax authority
portalYes

Lawyers, tax advisors, auditors, accountants,banks, notaries, persons referred to in I of Article
L.511-33 of the Monetary and Financial Code

Up to €100,000 per calendar year

Yes

_Adopted

Official language(But certain information can also
be reported in English)

Electronic / XML fileWeb-based form

Upload or direct data
entry to tax authority
portalYes_Lawyers, tax advisors, auditors

Up to €25,000 per violation

Yes

Tax return

AdoptedOnly in respectof Hallmarks D1& D2, other than
Cross-borderarrangements
involving Spainand Gibraltar inwhich case all
Hallmarks
apply.**

EnglishElectronic / XML file

Upload to tax authority
portal (once portal
available - in meantime,by email)__Lawyers acting in their capacity as lawyers

Up to £3,000 for providing inaccurate information

No_AdoptedEnglishElectronic / XML file

Upload to tax authority
portalNo(unless the reporting
person does not havea Greek tax ID)

NoLawyers and tax advisors that are acting in theircapacity as lawyers

Up to €100,000 per tax audit

No_Belgium

Bulgaria

Croatia

CyprusCzech Rep.

Denmark

Estonia

FinlandFranceGermany

Gibraltar

GreeceYes (if the reporting
person does not havea tax ID)

1

DAC6 Reporting Overview
Last update date: 22 April 2021

Member StateStatus

Guidance

Taxpayer annual reportingobligation

Primary reporting obligation for taxpayers and intermediaries

Major
departures from
DAC6

Reporting language

Reporting format

Filing mechanism

Pre-registration
required for DAC6filing

Signature / e-signing
required for filing

LPP exemption

Penalties

Hungary

Annual reportingobligation

Form of annual
reporting

Adopted

Official language or English(Optional)

Electronic / XML file
Electronic input form (ÁNYK)Upload to tax authority
portalNoNo

Lawyers

Default penalty up to HUF 500,000 (approx. EUR
1,500). Tax authority may levy default penalty of upto HUF 5,000,000 (approx. EUR 15,000) for noncompliance upon their specific requests

No_Adopted

EnglishElectronic / XML fileWeb-based form

Upload to tax authority
portalYes

Yes

Lawyers

Up to €500 per day per arrangement

Yes

Tax return

Adopted

Official language (Italian)with the description of thearrangement also in English

Electronic / XML file

Upload to tax authority
portalYes_Intermediaries exempt where examining juridical
status or could result in self-incrimination

Up to €31,500 per arrangement

Yes

Tax return

Adopted

Official language

Electronic / XML fileWeb-based form

Upload or direct data
entry to tax authority
portal*NoNo

Lawyers (sworn advocates)

Up to EUR 3,200No_AdoptedOfficial language or English(Optional)

Electronic / XML fileWeb-based form

Upload to tax authority
portal (encryption withprivate key is required)or direct data entry totax authority portal

Yes

Yes

Conditional LPP exemption€6,000 and status of non-reliable taxpayer

Yes_

Electronic / XML fileWeb-based form

Upload or direct data
entry to tax authority
portalYes

While signature / e-signing
not required for filing,authentication is required(LuxTrust) to accessofficial portal and submit
the report

Lawyers, auditors, chartered accountants€250,000 one-off fineYes

Tax returnIreland

Italy

LatviaLithuania

Luxembourg

Adopted

English (the interface is available
in English, French and German)

Adopted

EnglishElectronic / XML file
Excel Spreadsheet

UploadYesNo

Lawyers, tax advisors, auditors, notaries

up to €20,200 per reporting arrangement

No_Adopted

EnglishElectronic / XML fileWeb-based form

Upload or direct data
entry to tax authority
portalYes_Lawyers€870,000 per arrangement

No_Adopted

Official language

Electronic / XML fileWeb-based form

Upload to tax authority
portalNo

YesIntermediaries with legal professional secrecy

Up to app. Pln 27 000 000 (app. € 6 m)Yes(other periods
may also apply)

Separate form

Web-based form (XML or similarformat still expected)

Direct data entry to tax
authority portal

No, except the use of thepassword to access the tax
authority portal

Intermediaries with a contractual or legal
professional secrecyup to €80,000 one-off fine

Malta

Netherlands

PolandPortugalYes, but only
regardingSame as that for
arrangements
reportinginitially reported
arrangementby the relevant
taxpayer

Adopted

Official language or English(Optional for description ofarrangement and relevant
legislation only)

Adopted

Official language

Electronic / XML file
Electronic web-based form

Upload to tax authority
portalYes

Yes

Lawyers, tax advisors

up to 100.000 lei (approx. €20.000) per failure

Yes_Adopted

Official language and English(English language is preferred)

Electronic / XML file

Upload to tax authority
portalYes

Yes

lawyers, statutory tax advisors, statutory auditors€30,000 (can be imposed repeatedly)

No_Adopted

English (certain fields may beduplicated in official language)

Electronic / XML fileWeb-based form

Upload or direct data
entry to tax authority
portalDigital certificate
requiredYes

Lawyers

up to €30,000 in case of failure

Yes

Web-based form
(same as forregularreporting)

Adopted

Official language or English (theinterface will be available only inSpanish)Electronic / XML fileWeb-based form

Upload or direct data
entry to tax authority
portalNo*

Yes

Anyone performing "neutral assistance", meaning
giving only advice of the tax consequences of atransaction

Minimum fine 16.000 per violation up to one-off fine(amount of the fees received or due to theintermediary)

Yes

Separate form

Yes

Romania

Slovakia

Slovenia

Spain2

DAC6 Reporting Overview
Last update date: 22 April 2021

Member State

Status

Guidance

Reporting language

Reporting format

SwedenUnited Kingdom

Taxpayer annual reportingobligation

Primary reporting obligation for taxpayers and intermediaries

Major
departures from
DAC6

Filing mechanism

Pre-registration
required for DAC6filing

Signature / e-signing
required for filing

LPP exemption

Penalties

Annual reportingobligation

Form of annual
reporting

Adopted

Official language or English(Optional)

Electronic / XML fileWeb-based form
Paper-based report

Upload or direct data
entry to tax authority
portal*NoNoMembers of the Swedish bar association

SEK 315,000

No_Adopted
Only in respectof Hallmarks D1& D2EnglishElectronic / XML file

Upload to tax authority
portalYes_UK intermediaries that provide information withrespect to which a claim to legal professional
privilege could be maintained in legal proceedings

Up to £5,000 per arrangement

Yes

Tax return

Disclaimer: The information provided in this document is general in nature, at various stages of the legislative process and subject to regular update. This material has been prepared for general informational purposes only and is not intended to be relied upon as legal, accounting, tax or other professional advice.
*No specific DAC6 filing pre-registration required. However, access to the tax authorities’ portal (and e-filing system if applicable) is required to file any form if not already in place.
**Guidance for MDR cross-border arrangements (i.e., hallmarks D1 and D2) is to follow the OECD guidance. Please see link provided by the Gibraltar Competent Authority: https://www.oecd.org/tax/exchange-of-tax-information/model-mandatory-disclosure-rules-for-crs-avoidance-arrangements-and-opaque-offshore-structures.pdf

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