On 27 December 2019 and on 31 December 2019 Denmark published Law and Executive Order, simultaneously, for the implementation of Council Directive (EU) 2018/822 of 25 May 2018 (DAC6) on reportable cross-border tax planning arrangements (DAC6). This includes measures to require the reporting of cross-border tax planning arrangements and the exchange of information reported with other EU Member States.
The reporting requirement primarily applies to intermediaries that design, market, organize, or manage the implementation of a reportable arrangement, but may also apply to taxpayers in certain cases, such as when the intermediary is subject to confidentiality obligations or where a taxpayer has designed an arrangement without external intermediaries. The draft law also establishes penalties for reporting incomplete or false information. Under the Directive, the reporting requirements will apply from 1 July 2020, with initial disclosures required by 31 August 2020 in respect of reportable arrangements during the period 25 June 2018 to 30 June 2020.
