On 8 May 2020, the European Commission published a proposal to postpone the requirement to make first reports under DAC 6 by three months.

In doing so, the proposal recognises the disruptive effects of the coronavirus (COVID-19) pandemic on businesses and tax administrations.

Assuming this proposal is accepted by the EU Council and brought into EU and UK law, it will push back the deadline for submitting first reports under DAC 6 to:

  • 30 November 2020 for ‘historic’ pre-existing transactions (arrangements that became reportable from 25 June 2018 to 30 June 2020), and
  • the end of October for reporting new transactions (cross-border arrangements from 1 July 2020 to 1 October 2020).