DAC 6 - Not even a year old and already the first changes
It is February 2021 and the start date of DAC 6 is not even three months ago in many countries and twelve months ago in none. Now the new version 4.01 of the EU's XSD scheme (which, as of now, is not publicly available) is already available for transmission. This is to apply from the end of July / beginning of August.
The Federal Central Tax Office (BZSt) has already provided further information on the local implementation and a draft of the revised communication manual for the local scheme in version 1.07, but the BZSt also directly points out that further changes by the EU cannot be ruled out. Further short-term adjustments up to the implementation date are thus likely.
The EU's DAC 6 Directive (EU 2018/822) has already been implemented in various ways in the individual countries. It therefore remains to be seen to what extent further versions will lead to an ever greater heterogenisation of DAC 6 requirements within the area of application. Since there is to be an exchange of data within the EU, the member states have potentially tripped themselves up with the 27 or 28 different technical and professional implementations and have certainly not done themselves any favours, especially not the reporting companies. The wish of all reporting companies and also software manufacturers can only be a harmonisation of the already existing patchwork of requirements through further future versions. Because the initial technical implementations of the Directive have laid the foundation for this patchwork, it remains to be seen whether these wishes will be fulfilled at all.
It can be assumed that the first draft did not fully meet internal expectations, as a version update is already required. Any change in the requirements profile affects not only the software manufacturers, who have to keep up with the implementations in 27 or 28 countries, but also the reporting companies, which may have to transmit additional and/or deviating information. Accordingly, it is to be hoped that the update cycle will slow down in the future.
Further information and the documents referred to can be found on the DAC6 website of the BZSt: https://bit.ly/3qZDgBv.
Now the issue of DAC 6 is also before the ECJ for the first time: https://bit.ly/3kr1wKf