DAC6: Deferral Of Reporting Deadlines


In light of the COVID-19 pandemic, the Council of the European Union on 24 June 2020, adopted Directive 2020/876 which amended Directive 2018/822/EU as regards the mandatory automatic exchange of information in the field of taxation in relation to reportable cross-border arrangements (DAC6), giving the option to EU Member States to defer, by up to 6 months, the deadlines for the filing and exchange of information regarding reportable arrangements.


Following the aforementioned amendment, the Cypriot tax authorities, on 27 July 2020, announced that Cyprus has adopted the 6-month deferral for the filing and exchange of information. Accordingly, the new deadlines are as follows:


1)     Reportable cross-border arrangements which had been implemented between 25 June 2018 and 30 June 2020 must be reported by 28 February 2021.

2)     Reportable cross-border arrangements which were carried out between 1 July 2020 and 31 December 2020 must be reported within 30 days which start to count from 1 January 2021.

3)     Reportable cross-border arrangements which will be carried out from 1 January 2021 onwards must be reported within 30 days from the date the reportable cross-border arrangements are made available for implementation, or, are ready for implementation, or, when the first step in the implementation has been made, whichever occurs first.

4)     The first periodic report regarding marketable arrangements must be submitted by the intermediaries by 30 April 2021.


Notwithstanding that reporting deadlines of cross-border arrangements have been extended, reporting requirements under DAC6 remain the same. Therefore, individuals who are required to submit information on reportable cross-border arrangements are invited to maintain the necessary information for such arrangements in order to comply with their obligations. 


At Royal Pine & Associates we can assist you ensure compliance with the DAC6 national provisions and help you evaluate whether your planned or already implemented arrangements need to be reported. Drawing attention to our clientele, Royal Pine & Associates will conduct a preliminary review in order to determine whether any cross-border arrangements, which may need to be reported under the DAC6 provisions, have been executed by our clients since 25 June 2018.


The author of the article is Michalis Parides.

Michalis is a junior legal consultant at Royal Pine & Associates. He is a holder of an LL.B from the University of Essex and an LL.M from the University of Leeds.


* 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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