The tax authorities of all EU Member States will receive information on reportable cross-border transactions carried out by taxpayers. Subsequently, this information will be shared between the relevant tax authorities through automatic exchange of information.
A new European Directive requires that these transactions should be disclosed by the intermediaries involved (e.g. advisors) and, in certain cases, by the taxpayers. Cross-border arrangements might become reportable if they meet the criteria mentioned by the Directive and qualify as potentially aggressive tax planning arrangements.
The deadline for transposing these provisions into national legislation is 31 December 2019 and the first reporting process will take place in 2020. However, during this first reporting process, intermediaries and taxpayers will be required to disclose all information related to the qualifying structures implemented or provided for implementation after the date of entry into force of the Directive (June 25, 2018).