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Most of the EU Member States that deferred the DAC6 reporting deadlines due to the pandemic postponed them to February 28, 2021. Thus, the extended deadline for reporting cross-border arrangements satisfying at least one of the DAC6 hallmarks and whose first step was implemented on or after June 25, 2018 has passed. 

However, EU Member States still are navigating the DAC6 landscape, with States frequently deviating in implementing and interpreting the rules. While some EU countries have published guidelines, the interpretation of key requirements for certain hallmarks and concepts remains unclear.  

Despite the challenges, the EU is committed to begin the exchange of information on reportable cross-border arrangements between European tax authorities on April 30, 2021.