Grant Thornton Survey

Reporting obligations on cross border tax arrangements

Marion Frotscher Marion Frotscher

The implementation of EU directive 2018/822 (DAC-6) regarding the reporting obligations on cross border tax arrangements is continuing to move forward in the EU member states. This results from the current survey within the Grant Thornton Network in comparison to the first survey in March of this year (the results of this survey can be found here). The results of the current survey are summarized in the graphic below.


The results of the survey have significantly changed since our last survey in March. Whereas only a few member states had published legislative proposals back then, the member states with a proposal has now almost doubled. Therefore currently more than half of the EU member states have a legislative proposal or have already implemented the directive. Slovenia and Lithuania have now joint Poland in the category of countries which have already implemented the directive.

Significant differences between the member states also exist with regards to the maximum fines for non-compliance with the reporting obligations. With maximum fines of up to EUR 5 Mio. Poland so far has the highest maximum fines within the EU. Slovenia with EUR 10,000 for sole traders (EUR 15,000 for small and EUR 30,000 for medium and large enterprises) on the other hand has rather moderate fines. In all countries the fines can be imposed on natural persons or the company.

The reporting obligation has to be complied with by reporting through a government issued digital form in 6 countries. Only Sweden and Latvia so far also allow reporting though a physical form.

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.