Who is affected by DAC6? Who is affected by DAC6? Who is affected by DAC6?

• The Swiss headquarters of an international pharmaceutical group receives royalties from its German subsidiary that are preferentially taxed in Switzerland
• This transaction may fall under hallmark C.1(d) of the Directive: An arrangement that involves a deductible cross-border payment and the payment benefits from a preferential tax regime in the jurisdiction of the recipient
• This transaction is generally reportable by the German subsidiary under DAC6

• A relationship manager of a Swiss bank advises a German resident client to invest part of his funds through a life insurance policy that is preferentially taxed in Germany 
• This asset restructuring could fall under hallmark B.2: An arrangement that has the effect of converting taxable income into capital, gifts or other categories of revenue which are taxed at a lower level or exempt from tax
• As there is no EU intermediary involved, the German client might be required to report this transaction to the German tax authorities

• A Swiss trading company acquires hard-to-value trademarks from a group company domiciled in Ireland
• This transaction could be captured by E.2: An arrangement involving the transfer of hard-to-value intangibles
• This transaction is generally reportable by the Irish company

• DAC6/EU MDR – Overview and implications for Swiss banks
• EU Mandatory Disclosure Rules (DAC6) – How are corporate groups affected?
  

We can provide training sessions on the DAC6 requirements, tailored to the specific requirements of your organization.

It’s important to understand the potential impact of DAC6 on your organization. Our detailed assessment includes an in-depth analysis of products and transactions (both in-house and with regard to clients) that could be in scope, as well as a comparison of the detailed requirements across affected jurisdictions.

Once the impact of DAC6 on your organization has been determined, we can assist you in establishing appropriate policies, setting up processes accordingly and implementing required mechanisms for ongoing monitoring and potential reporting.

KPMG has developed the KPMG MDR Processor to optimize MDR processes. With reporting features for all EU countries, this tool supports efficient workflow management to identify your reportable arrangements.