DAC6 Directive: Key Reporting Rules Across EU Countries

The DAC6 Directive (EU 2018/822) introduced Mandatory Disclosure Obligations across the European Union for a broad range of cross-border tax arrangements, aiming to increase tax transparency and combat aggressive tax planning.

While EU member states have generally aligned their legislation with DAC6, several jurisdictions have added their own nuances and additional requirements. Understanding these differences is essential for intermediaries and taxpayers operating across borders.

Our network's tax lawyers have compiled a clear, country-by-country overview covering the practical implementation of DAC6 in Luxembourg, Hungary, and Italy. The report outlines key differences, including:

• Scope of reportable arrangements and hallmarks

• Who must report — intermediaries and/or taxpayers

• Deadlines and penalties

• Interpretations of legal professional privilege

• National guidance and implementation challenges

Each jurisdiction’s interpretation reflects its legal culture and administrative approach, making this comparative guide a useful reference for advisors navigating multi-jurisdictional compliance.