DAC6 deadlines confirmed: options to submit reports
In our blog article dated July 8, 2020, we discussed that the deadlines for DAC6 reporting would not be extended. This means that effective from July 1, 2020, taxpayers in the EU are required to report on cross-border tax planning activities within 30 days from the day they started. Transactions and arrangements between June 25, 2018 and June 30, 2020 must be reported by August 31, 2020.
A (final) circular of the German Ministry of Finance interpreting the terminology, hallmarks and the reporting procedure is expected to be published on July 15, 2020. The circular is not expected to present major changes as compared to the previous (unofficial) draft circular of June 12, 2020.
Options to submit DAC6-reports
The German Federal Central Tax Office (BZSt) has recently published version 1.1 of the communication manual “Automatic Exchange of Tax Arrangements (DAC6) – Procedure description, feedback and business rules” on June 29, 2020.
The communication manual also provides detailed information on the submission process. BZSt offers three options to submit DAC6-reports:
- Individual data transmission via the BZSt Online Portal (BOP): The data for each individual report is entered into the BOP Online Form manually and then transmitted to the BZSt. This is mainly suitable for the transmission of small numbers of reports and does not require any technical expertise.
- XML Web Upload in the BOP: XML-files are uploaded directly via the BOP. This reporting option is recommended for the transmission of small to medium numbers of reports and requires medium technical expertise or a DAC6 XML converter.
- Electronic Mass Data Interface (ELMA): The data is automatically submitted in XML-format via the ELMA interface. ELMA is recommended for the transmission of large numbers of reports but requires a high level of technical expertise. Most DAC6 tools will use the ELMA interface, where users will be benefiting from the technological advantages of ELMA and of a customized interface.
For all procedures, an active BZSt-number and a valid BOP-certificate are required.
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Disclaimer: We assume no liability for the accuracy of the information. The information listed here does not constitute recommendations for action.