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EU Mandatory Disclosure Rules (MDRs/ DAC6)

Transposition and reporting overview

Country

Transposition status

Guidance

Deferral of reporting deadlines

Waiver for Legal Professional Privilege

Reporting

Comments

 

 

 

 

Available

Applies to tax advisors(2)

Format

Filing possible as of

Reporting language

Registration required(1)

 

Austria

In force (July 1, 2020)

Draft

Yes (3 months)

Yes

Yes

Paper forms or Manual data entry

October 1, 2020

English and Local language

No information available

 

Belgium

In force (July 1, 2020)

Final

Yes (6 months)

Final (except for submission process)

Unclear - subject to dispute

File upload

Unknown

English and Local language(s)

No information available

 

Bulgaria

In force (July 1, 2020)

Not published

Yes (6 months)

Yes(3)

No

No information available

Unknown

No information available

No information available

 

Croatia

In force (July 1, 2020)

Not published

Yes (6 months)

Yes

Yes

Manual data entry

Unknown

English and Local language

Yes

 

Cyprus

Pending

Not published

Yes (6 months)

Yes

No

File upload

Unknown

English

No information available

 

Czech Republic

In force (August 29, 2020)

Not published

Yes (6 months)

Yes

Yes

File upload

Unknown

No information available

No information available

 

Denmark

In force (July 1, 2020)

Final

Yes (6 months)

Yes

No

Manual data entry

July 1, 2020

Local language

Yes

Read Denmark comments

Estonia

In force (July 1, 2020)

Draft

Yes (6 months)

Yes

No

Paper forms

Unknown

Local language

No

 

Finland

In force (July 1, 2020)

Final

No

Yes(4)

No

File upload

July 1, 2020

English or Local language

Yes

 

France

In force (July 1, 2020)

Draft(6)

Yes (6 months)

Yes

Yes

Paper forms or Manual data entry or File upload or End-to-end interface

Unknown

Local language

No information available

 

Germany

In force (July 1, 2020)

Draft(6)

No

Yes(4)

Yes

Manual data entry or File upload or End-to-End Interface

July 1, 2020

Local language

Yes

Read Germany comments

Greece

In force (July 1, 2020)

Not published

Yes (6 months)

Yes

No

No information available

Unknown

No information available

No information available

 

Hungary

In force (July 1, 2020)

Not published

Yes (6 months)

Yes

No

Manual data entry e-form

Unknown

English and Local language(*)

No information available

Read Hungary comments

Ireland

In force (July 1, 2020)

Final

Yes (6 months)

Yes

No

Manual data entry or File upload

Unknown

English

Yes(*)

Read Ireland comments

Italy

In force (August 26, 2020)

Not published

Yes (6 months)

Yes(*)

Yes(*)

No information available

Unknown

No information available

No information available

Read Italy comments

Latvia

In force (July 1, 2020)

Final

Yes (6 months)

Yes

No

Manual data entry or File upload

Unknown

Local language

No information available

 

Lithuania

In force (July 1, 2020)

Draft

Yes (6 months)

Yes

Yes

No information available

July 1, 2020

No information available

No information available

 

Luxembourg

In force (July 1, 2020)

Final

Yes (6 months)

Yes

Yes(*)

File upload or End-to-end interface

January 1, 2021(*)

English, French, German(*)

No information available

Read Luxembourg comments

Malta

In force (July 1, 2020)

Not published

Yes (6 months)

Yes

Yes

No information available

Unknown

English and Local language

No information available

 

Netherlands

In force (July 1, 2020)

Final

Yes (6 months)

Yes

No

Manual data entry or File upload

January 1, 2021

English

Yes

 

Poland

In force (January 1, 2019)

Final

Other deferral(5)

Yes(4)

Yes

Manual data entry or File upload or End-to-end interface

July 1, 2020

Local language

No

 

Portugal

In force (July 1, 2020)

Not published

Yes (6 months)

Yes

Yes(*)

No information available

Unknown

No information available

No information available

Read Portugal comments

Romania

In force (July 1, 2020)

Not published

Yes (6 months)

Yes

Yes

Paper forms or Manual data entry or File upload

Unknown

English and Local language

Yes

 

Slovakia

In force (July 1, 2020)

Not published

Yes (6 months)

Yes

Yes

No information available

Unknown

Local language

Yes

 

Slovenia

In force (July 1, 2020)

Final

Yes (6 months)

Yes

No

Manual data entry

July 1, 2020

English

No information available

 

Spain

Pending

Not published

No information available

Yes

Yes

File upload or End-to-end interface

Unknown

English and Local language

Yes

 

Sweden

In force (July 1, 2020)

Final

Yes (6 months)

Yes(3)

No

Paper forms or Manual data entry or File upload

July 1, 2020

English and Local language

Yes(*)

Read Sweden comments

United Kingdom

In force (July 1, 2020)

Final

Yes (6 months)

Yes

No

File upload or End-to-end interface

Unknown

English

No information available

 

Country Comments

  • Denmark: Current reporting solution is only in Danish language, but the description of the arrangement can be completed in English.
  • Germany: German draft guidance allows for the option to submit some of the required information in English. However, this will not relieve taxpayers from also reporting the that information in German language.
  • Hungary: The form is in Hungarian, however the description of the arrangement could be in English, up to 4000 characters.
  • Ireland: Current indication is that registration will be required.
  • Italy: Legal professional privilege (LPP applies) only to information received by the intermediary from the client during the intermediary’s analysis of the client's legal position or while representing the client before a court. LPP applies to tax advisors in respect of the information mentioned above.
  • Luxembourg: *Only tax advisors that are part of a qualifying firm (e.g. chartered accountancy or audit) are covered by LPP. This is the case of KPMG, for example, but not of all tax advisors in Luxembourg. *The possibility to report starting from January 1, 2021 is a prudent position by the authorities. *It is expected that filing will be possible in English, French or German, which is the case for other returns in Luxembourg.
  • Portugal: Note that a waiver may be available for both legal and contractual LPP in Portugal.
  • Sweden: Obtaining a filing certificate is required for online submission.

Footnotes

(*) See comments section.

(1) Registration on Tax Authority website or obtaining a filing certificate required for submission.

(2) In additional to lawyers, the scope of LPP also covers tax advisors that are not registered lawyers.

(3) Where LPP applies, exempt advisors have certain reporting obligations (e.g. to notify the revenue authorities about other advisors and/or taxpayers participating in the arrangement).

(4) Intermediaries are required to file an anonymous (i.e. excluding client-specific information) or simplified report when LPP is applicable.

(5) Please refer to KPMG's EU Tax Centre e-news issue 120 for further details (https://home.kpmg/xx/en/home/insights/2020/08/e-news-120.html).

(6) Draft guidelines issued and enforceable in the current form, but potentially subject to change.