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The EU-member states are obliged to implement the reporting obligations on cross border tax arrangements laid down in the EU directive 2018/822 (DAC-6) into their national laws. The new legislation shall be in place by December 31st 2019 at the latest. The application of the new provisions is scheduled to begin on July 1st 2020. In order to track the current status of the national law proposals in the individual member states a survey was conducted within the Grant Thornton Network. The survey shows significant differences in the progress of the implementation and the intended content of the new laws. Only Poland has already implemented the directive into national law. In a few member states a legislative proposal has so far been published. The majority of the countries, however, has not published any legislative proposals yet. With regards to the content nine countries are so far planning on implementing exemptions from the reporting obligations for professional secrecy holders (e.g. tax advisors, lawyers) in their national laws. As of now Germany, Bulgaria and Portugal are planning a reporting obligation for purely national tax arrangements beyond the compulsory implementation of the reporting obligations on cross border tax arrangements. Poland has already implemented such a reporting duty. The results of the survey are summarized in the graphic below. We will keep you updated on the further developments of the implementation. In case of any questions please contact our expert for international taxation Dr. Marion Frotscher.

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