Retroactive reporting obligation means the clock is ticking even faster
What makes DAC6 an even bigger issue is the fact that taxpayers and intermediaries do not just have to report future transactions, but also some that have already been completed. In cases where implementation of the arrangement began at any point between 25 June 2018 and 1 July 2020, the information must be reported by 31 August 2020. Therefore, we recommend taking appropriate action now rather than leaving it until later.