KPMG’s DAC6 Managed Service reporting solution is designed to assist businesses with their reporting obligations. This is a tailored approach ranging from assisting business with reviewing potentially disclosable transactions to submitting disclosures on behalf of businesses using KPMG’s proprietary DAC6 reporting technology.
For certain arrangements entered into since 25 June 2018 companies operating in multiple jurisdictions could have mandatory reporting obligations under DAC 6. This reporting is required when certain cross border transactions take place and meet one or more specific hallmarks.
Although the aim is to counter tax planning, DAC 6 captures a wide range of arrangements because some hallmarks do not require a tax benefit to be present. It is possible that tax authorities will not only audit the arrangements which have been reported to them but also challenge the rationale for not reporting others.
There is already divergence across EU Member States in the way they have implemented the rules and reporting deadlines and compliance with local implementation is proving challenging. As DAC 6 applies retrospectively with effect from 25 June 2018, the disclosure obligations need to be documented and tracked now. Some countries have already introduced 30 day reporting and others are due to follow shortly.