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 |
|
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 |
|
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 |
|
Ireland |
In force (July 1, 2020) |
Final |
Yes (6 months) |
Yes |
No |
Manual data entry or File upload |
Unknown |
English |
Yes(*) |
|
Italy |
In force (August 26, 2020) |
Not published |
Yes (6 months) |
Yes(*) |
Yes(*) |
No information available |
Unknown |
No information available |
No information available |
|
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 |
|
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 |
|
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(*) |
|
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.
