On 12 July 2019, the Dutch Ministry of Finance published the legislative proposal containing the Dutch implementation of the Mandatory Disclosure Rules (Directive 2018/22/EU) or the 6th amendment to the EU directive on Administrative Cooperation (Directive 2011/16/EU) (hereinafter ‘DAC6’). The proposal includes a bill and an explanatory memorandum. A consultation document was already published on 19 December 2018. Further guidance in relation to the legislative proposal is expected.
As required under the directive, the proposed legislation is intended to be implemented as per 1 July 2020. However, the directive already entered into force per 25 June 2018, with the obligation to report with retroactive effect per 1 August 2020 on transactions entered into between 25 June 2018 and 1 July 2020.
In relation to the legislative proposal, please find below our initial observations for the real estate (RE) and financial services (FS) industry.
