DAC 6 – Filing of information on reportable domestic and cross-border arrangements: postponement of deadlines

In brief

Decree-Law no. 53/2020, of 11 August, transposes into national law Council Directive (EU) 2020/876, of 24 June 2020, that amends Directive 2011/16/EU, of 15 February, on administrative cooperation in the field of taxation.

In detail

The Decree-Law postpones the deadlines to file information on reportable domestic and cross-border arrangements, foreseen in Law 26/2020, of 21 July, as follows:

• Information on reportable cross-border arrangements the first step of which was implemented between 25 June 2018 and 30 June 2020 – to be filed by 28 February 2021;
  
• Reportable domestic or cross-border arrangements made available for implementation or ready for implementation, or where the first step in its implementation has been made between 1 July 2020 and 31 December 2020 (also applicable to intermediaries having provided, directly or by means of other persons, aid, assistance or advice concerning a reportable arrangement) - the period of 30 days for filing information to begin by 1 January 2021;
  
• Situations covered by legal or contractual secrecy involving the filing of information on reportable domestic or cross-border arrangement made available for implementation or ready for implementation, or where the first step in its implementation has been made between 1 July 2020 and 31 December 2020 – the period of 5 days to inform the taxpayer to begin by 1 January 2021;
  
• Domestic and cross-border marketable arrangements – first periodic report to be filed by the intermediary by 30 April 2021.
  

^{© 2020 PwC. This communication is of an informative nature and intended for general purposes only. It does not address any particular person or entity nor does it relate to any specific situation or circumstance. PricewaterhouseCoopers Tax Services TLS, Lda. We will not accept any responsibility arising from reliance on information hereby transmitted, which is not intended to be a substitute for specific professional business advice.}