Reporting on international tax planning arrangements begins in the summer

News, 6/22/2020

The Tax Administration has published guidance on the new reporting obligation related to cross-border tax planning arrangements. The reporting obligation starts at the beginning of July, but any previous arrangements made during the transition period must be reported by the end of August.

On 30 April 2020, the Tax Administration published detailed guidance and reporting instructions on the application of the act on reportable arrangements in the field of taxation and of the related amendments made to the Act on Assessment Procedure.

Cross-border tax planning arrangements with characteristics of tax avoidance or tax evasion must be reported to the Tax Administration. The reporting obligation concerns arrangements which include parties from more than one country and which have at least one of the characteristics defined in the legislation.

This reporting obligation is new, and it concerns arrangements implemented by companies and by individuals. Service providers and taxpayers must report the cross-border tax planning arrangements referred to in the legislation as of 1 July 2020 to the Tax Administration. Each arrangement must be reported within 30 days after it has been made available, it is ready to implemented, or its first phase has been implemented.

The act on reportable cross-border arrangements is based on the DAC6 EU directive, whose objective is to increase transparency in taxation and to prevent aggressive cross-border tax planning.

All arrangements implemented during the transition period after the directive entered into force, i.e. after 25 June 2018, must be reported by the end of August. The report should be filed in the service. In exceptional cases, the report may be filed on paper.


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