The recent approval of the European enabling Law 2018 allows for the transposition of the EU Council Directive 2018/822 dated 25 May 2018 on cross-border mechanisms subject to reporting obligations, the so-called DAC 6, within the deadline of 31 December 2019. The outline of the transposing Legislative Decree has long been communicated, and submitted for public consultation by the MEF in order to acquire assessments, comments and suggestions from the professional community. However, significant doubts remain, in terms of interpretation and application, that will have to be addressed by the final text of the Transposition Decree in order to allow companies and intermediaries to comply with the new disclosure requirements as early as next year, with retroactive reference to operations carried out as of June 25, 2018. These new disclosure obligations, which are part of the new OECD system to combat international tax evasion, should be balanced by new instruments made available to taxpayers to achieve a higher level of tax certainty at the international level.

Annex