DAC6: The Next Step in Automatic Exchange of Information

The international drive toward greater fiscal transparency has given rise to a range of tax information exchange regimes. Against that backdrop of global demand for greater tax transparency, the E.U. has issued Council Directive 2018/822 of May 25, 2018, which is widely referred to as “DAC6.” It is particularly important for fund managers to understand DAC6 because it requires compliance with various filing deadlines, which have been extended to fall over the next several months. In a guest article, Will Smith and Lily Teh, partner and associate, respectively, at White & Case, provide an overview of historical disclosure and exchange initiatives; describe recent developments in the disclosure and automatic exchange of information landscape; summarize DAC6; and discuss how DAC6 might impact investment managers and the investment funds industry. For more from Smith, see “Practical Tax Considerations Arising From Trends in European Fund Structuring” (Jun. 13, 2019).

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