Portugal transposed the EU DAC6 rules into law on July 21. This EU Directive covers the mandatory automatic exchange of tax information related to reportable cross-border arrangements. Following this implementing law, the Portuguese tax authorities (PTA) published guidelines on the practical implementation of DAC6 in Portugal. The PTA’s guidelines may create unexpected reporting obligations in Portugal for a ‘relevant taxpayer’ regarding cross-border arrangements when a Portuguese nexus exists.
The takeaway: While many taxpayers have been subject to DAC 6 reporting obligations for a while, these Portuguese guidelines add a new level of complexity with possible additional reporting requirements.