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

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