DAC 6: Further Stretching of Reporting Deadlines and Update of Submission Process


The domestic transposition of the EU Council Directive 2018/822, commonly known as DAC6, was expected to take place within February 2021. To this effect, the Cyprus Tax Department had recently announced that compliance with reportable obligations under DAC6 was extended to 31 March 2021.


On 4 June 2021, the Cyprus Tax Department announced a further extension and confirmed no fines will be charged for late submission until 30 September 2021, for the following cases:

  1. Reportable cross-border arrangements which were implemented between 25 June 2018 and 30 June 2020 and had to be submitted by 28 February 2021.
  2. Reportable cross-border arrangements held between 1 July 2020 and 31 December 2020 and had to be submitted by 31 January 2021.
  3. Reportable cross-border arrangements held between 1 January 2021 and 31 August 2021, which had to be submitted within 30 days from the date they were made available for implementation or were ready for implementation or the first step in the implementation was made, whichever occurred first.
  4. Reportable cross-border arrangements for which secondary intermediaries provided aid, assistance or advice, between 1 January 2021 and 31 August 2021 and had to submit information within 30 days beginning on the day after they provided aid, assistance or advice.


It is worth noting that the information to be submitted for reportable cross-border arrangements also includes information on persons associated with the taxpayer concerned, in accordance with the Administrative Cooperation in the Field of Taxation Law L.205 (I)/2012, as amended. Therefore, information should be provided for companies and individuals who are direct shareholders of the taxpayer concerned. In this regard, the Cyprus Tax Department has updated the sample XML file available on their website by adding fields for the affiliated companies and associates of the taxpayer concerned, to be completed as per the instructions provided therein.


At Royal Pine & Associates Limited we can assist you by ensuring compliance with DAC6, help you evaluate whether your arrangements are reportable under DAC6 and assist in the filing procedure.



The author of the article is Anastasia Sarkisian.

Anastasia is a legal consultant at Royal Pine & Associates. She is qualified lawyer with experience in the corporate field and admitted member at the Cyprus Bar Association.


* This publication has been prepared as a general guide and for information purposes only. It does not purport to be comprehensive or to render legal advice. 

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