Germany’s Ministry of Finance has announced that the government will not postpone the deadlines for the filing and exchange of cross-border financial account information and tax planning arrangements by six months.
According to MOF spokesperson Kristina Wogatzki, the government announced July 6 that the reporting obligations of the sixth directive on administrative cooperation (DAC6) began July 1. Under the directive, the first reporting deadline for intermediaries and relevant taxpayers is August 31.
The EU Council on June 24 adopted an amendment to Directive 2011/16/EU (the administrative cooperation directive) “to address the severe disruptions created by the COVID-19 pandemic,” according to a council release. The amendment permits EU member states to delay by six months deadlines for filing and exchanging information on reportable cross-border tax planning arrangements, and for automatic exchanges of information on financial accounts for beneficiaries that are tax residents in another member state.
According to the amendment, for reportable cross-border arrangements made between June 25, 2018 (when DAC6 entered into force), and June 30, 2020, the deadline to file may be extended to February 28, 2021. In cases in which reportable cross-border arrangements were implemented or ready to be implemented between July 1 and December 31, 2020, the 30-day filing period would begin January 1, 2021.
The Irish Revenue Commissioners announced in a July 3 release that "in light of the restrictions imposed on businesses during the COVID-19 pandemic," it is exercising the option given to it by the council and postponing by six months the filing dates for the first returns related to reportable cross-border arrangements. The Revenue Commissioners published guidance on how the regime will operate.
The Netherlands also announced in an updated FAQ that it will postpone its reporting deadline by six months as a result of the pandemic.
Luxembourg, the Czech Republic, and Finland have all exercised the option to delay the DAC6 reporting requirements. The Danish government issued an executive order (BEK No. 1049) extending the reporting deadlines on June 29. France and Hungary are reviewing draft legislation to delay the deadlines.