Recently, Estonia has published Tax Information Exchange Act (Amendment) in the Official Gazette for the implementation of Council Directive (EU) 2018/822 of 25 May 2018 (DAC6) on reportable cross-border tax planning arrangements (DAC6).
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 Amendment Act also establishes penalties for reporting incomplete or false information. The Amendment Act entered into force from 1 January 2020. 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.
