Danae Daniel
As of March 18 2021, the Cyprus Parliament voted the Directive 2018/822 (DAC6) into Law. The voting of DAC6 was also published in Cyprus Gazette on March 31 2021.
The new DAC6 Directive requires that EU intermediaries and taxpayers submit information to the Tax Authorities with which they have an EU nexus, regarding cross border arrangements that meet at least one of the “hallmarks”.
Following the COVID-19 pandemic, the deadlines which were initially extended by six months, will carry no imposition of administrative fines for overdue submission of the DAC6 information if they are submitted until June 30 2021, as per the Cyprus Tax Authorities’ relevant announcement. This exemption applies to the following cases:
- Reportable cross-border arrangements, which were first implemented between June 25 2018 and June 30 2020 (“the transitional period”) and had to be submitted by February 28 2021;
- Reportable cross-border arrangements, held between July 1 2020 and May 31 2021, that 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;
- Reportable cross-border arrangements, for which secondary intermediaries provided aid, assistance, or advice, between July 1 2020 and May 31 2021 and had to submit information within 30 days beginning on the day after they provided aid, assistance, or advice. As from June 1 2021, a 30-day rolling window for submission of reportable cross-border arrangements will apply.
Royal Pine is able to assist you in ensuring compliance with the DAC6 Directive and help you evaluate whether your planned, or already implemented, arrangements need to be reported.
* 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.
