The deadline for the communication of reportable mechanisms is 2021.
On June 3, 2020, Member State representatives on Coreper (the Permanent Representatives Committee) reached political agreement on an optional six-month deferral of reporting deadlines under the EU Mandatory Disclosure Rules (“DAC6”).
In order for the deferral to become applicable, formal unanimous agreement in the Council of the European Union is required. In addition, an opinion is required from the European Parliament, which is expected by the end of the month. It will then be up to each Member State to opt for and communicate the deferral.
According to DAC6, the reporting obligations of relevant arrangements should start as from 1 July 2020, while arrangements whose first step has occurred or will occur between 25 June 2018 and 30 June 2020, should take place by 31 August 2020.
With the political agreement now reached and in case Portugal exercises the option for the deferral – as is happening with several other Member States, – the deadline for the communication of reportable mechanisms that occurred between 25 June 2018 and 30 June 2020 will pass to 28 February 2021, while reportable mechanisms occurring between 1 July 2020 and 31 December 2020 must be communicated within 30 days from 1 January 2021.
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