Mandatory automatic exchange of information in the field of taxation for reportable cross-border arrangements (DAC 6)

On 25 May 2018, the Economic and Financial Affairs Council formally adopted the Council Directive amending the existing Directive 2011/16/EU on administrative cooperation in the field of taxation, as regards mandatory automatic exchange of information in relation to reportable cross-border arrangements to disclose potential aggressive tax plannings. The Directive has been in force since 25 June 2018.

The main objective of the Directive 2018/822 ("DAC 6") is to strengthen tax transparency by way of automatic exchange of information between the EU Member States on potentially “aggressive tax planning” arrangements.

Any transaction involving two countries where at least one is in an EU country will need to be reported where it meets certain criteria (referred to as "HALLMARKS") that could indicate aggressive tax planning.

The obligation to disclose is on all EU-based intermediaries involved in the arrangement. Under certain conditions the taxpayer may be obliged to disclose as well.

How we can help

Our team combines experts in tax, people, processes, data and technology. By bringing together these different skill sets, we can help taxpayers understand the new rules and implement effective controls and processes to ensure disclosable events are proactively identified and managed.

  • Risk assessment (per business unit) underpinned by a tried and tested methodology to help you assess:
    • key risk areas and processes,
    • applicable hallmarks,
    • your impacted businesses, and
    • readiness to comply.
  • Review of a (sample) of transactions


  • Comprehensive documented framework to identify and manage risks and potentially impacted transactions.
  • Define roles and responsibilities.
  • Draft and review procedures
  • PwC DAC 6 Smart Reporting to monitor in-scope transactions


  • On-site training with our specialists.
  • EU Mandatory Disclosure Regime e-learn module
  • Ad hoc advisory
  • Regulatory intelligence


  • DAC 6 reporting
  • Integrated approach using technology to address multiple reporting requirements using the same data set and reporting mechanism in the required format.


DAC6 in national motion: Are you up for the challenge?

DAC6 is an EU directive that introduces reporting obligations for a wide range of cross-border tax arrangements. Many EU countries have already aligned their national laws quite closely to the directive. Some countries went beyond it, adding extra requirements to their local laws. These differences may add complexity whenever international businesses set out to comply. Are you up for the challenge?

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DAC6 in national motion: Are you up for the challenge?

Contact us

Sidonie Braud

Tax Partner, AWM Tax Leader, PwC Luxembourg

Tel: +352 49 48 48 5469

Murielle Filipucci

Tax Partner, Global Banking & Capital Markets Tax Leader, PwC Luxembourg

Tel: +352 49 48 48 3118

Géraud de Borman

Tax Partner, Insurance, PwC Luxembourg

Tel: +352 49 48 48 3161

Pierre Kirsch

Tax Partner and Authorised Manager of the PSF, PwC Regulated Solutions S.à r.l.

Tel: +352 49 48 48 4031

Alina Muntean

Tax Partner, Alternatives, PwC Luxembourg

Tel: +352 49 48 48 3167

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