On 19 September 2019, the Austrian Parliament passed a law implementing Council Directive 2018/822 of 25 May 2018 amending Council Directive 2011/16/EU on Administrative Cooperation in the field of taxation in relation to reportable cross-border arrangements (the so-called “DAC6”).
In brief, DAC6 obliges service providers or, alternatively, taxpayers to report on cross-border tax planning arrangements that meet certain hallmarks.
On the basis of the wording of the law, there are still many open questions, especially in connection with the concept of the intermediary and the concrete scope of the hallmarks. A decree with explanatory examples will be published by the BMF in the near future.
