On 8 May 2020, the EU Commission has proposed a number of amendments to the DAC6 Directive governing reportable cross-border arrangements. On the basis of the proposal, the Finnish tax authority published a guideline. The Act on the Reporting Obligation for Cross-Border Tax Planning Structures entered into force at the beginning of 2020. The Act is based on the European Union’s DAC6 Directive concerning cross-border arrangements, which entered into force on 25 June 2018.
The reporting obligation applies to tax planning structures in which the parties to an arrangement are from more than one Member State and the arrangement includes at least one of the distinguishing hallmarks defined in the Act. A distinguishing hallmark is an attribute or characteristic that indicates tax avoidance.
Reportable information consists of the identification details of the persons and companies involved in the arrangement and information on the reportable arrangement, such as a description of the arrangement and the national provisions of which it takes advantage. Finland exchanges reportable information with the other EU Member States on the basis of the Directive. The exchange of information enhances tax control and makes tax evasion more difficult.
