Against the background of the COVID-19 pandemic, the EU Commission has proposed postponing the DAC6 reporting deadlines by 3 months (with the possibility of a further postponement of 3 months):
- The start of the 30-day period for reporting new transactions will be postponed from 1 July 2020 to 1 October 2020.
- Accordingly, agreements implemented from 1 July 2020 onwards must be reported for the first time by 31 October (instead of 31 July) 2020.
- "Historical agreements" (i.e. arrangements implemented between 25 June 2018 and 30 June 2020) will have to be reported by 30 November (instead of 31 August) 2020.
This postponement can then be extended again by a maximum of three months if the COVID-19 situation in the EU Member States requires a further delay of the reporting deadlines.
This proposal of the EU Commission still has to be approved by the EU Parliament and the EU Council. However, we assume that it is a formality, in particular given that the retroactive effect back to 25 June 2018 will remain unchanged, i.e. EU member states will receive exactly the same data, simply three months later.