On 25 May 2018, the the Economic and Financial Affairs Council (ECOFIN) formally adopted rules regarding the mandatory automatic exchange of information in relation to reportable cross-border arrangements (commonly referred to as DAC6).
The main purpose of DAC6 is to strengthen tax transparency and fight against aggressive tax planning. The term aggressive tax planning is not defined, and reference is made instead to a number of pre-determined hallmarks, which are features that could render a cross-border arrangement reportable under this Directive. DAC6
provides for mandatory disclosure of cross-border arrangements by intermediaries or taxpayers (both individual or corporate) to the tax authorities and mandates automatic exchange of this information among EU Member States.