DAC6 reporting deadline — 30 days from the trigger
Deadlines: the full filing calendar · the regulation library · practical guides
DAC6 has no annual date. The clock runs from an event, so the control has to sit inside deal workflow rather than in a filing calendar. In the EU the filing is due within 30 days of the earliest of the three trigger events in Article 8ab(1). Source: Council Directive (EU) 2018/822, Article 8ab(1). It lands on the AIFM or management company and the investment adviser.
What is DAC6 reporting?
DAC6 is the EU regime for mandatory disclosure of reportable cross-border tax arrangements. An arrangement is reportable when it is cross-border and meets at least one hallmark, some of which apply only where a tax advantage is a main expected benefit. It has no annual date: the clock runs from an event (EU Commission: DAC6).
What is in the report
A report gives the intermediaries and taxpayers involved, the hallmark that applies, a summary of the arrangement, its value, the member states concerned, and the national rules it relies on.
Who files, who prepares, who receives
The intermediary reports first, meaning whoever designs, markets, organises or manages the arrangement, plus advisers who help. Where the intermediary has legal privilege it must tell the others to report. Where there is no EU intermediary at all, the duty falls on the taxpayer. Reports go to a national tax authority.
When it is due
| Jurisdiction | Obligation | Due | Reporting period | Who files | Files with | Extension | Source |
|---|---|---|---|---|---|---|---|
| EU | DAC6 — disclosure of a reportable cross-border arrangement | within 30 days of the earliest of the three trigger events in Article 8ab(1) | set by the rule | the AIFM or management company and the investment adviser | — | — | Council Directive (EU) 2018/822, Article 8ab(1) · calendar |
Common mistakes
Three triggers run at once, and the earliest one starts the clock. An arrangement can be ready to use long before anyone uses it, and the thirty days begin there. Waiting for the first real step is how the window closes unnoticed. Two more catch people: some hallmarks must be reported even with no tax-saving motive; and a reusable, off-the-shelf arrangement needs a fresh report every three months.
Questions this page answers
When is a DAC6 report due?
Within thirty days, beginning the day after the arrangement is made available for implementation, the day after it is ready for implementation, or when the first step is taken. The earliest of the three starts the clock.
Who has to file the DAC6 report?
The intermediary, meaning whoever designs, markets, organises or manages the arrangement. Where no intermediary is within scope, the relevant taxpayer reports instead.
Is there a recurring DAC6 filing?
For a marketable arrangement, yes. Article 8ab requires a periodic report every three months updating the new reportable information that has come to light since the last one.
Where is a DAC6 report filed?
With a national tax authority, through that member state's own portal. Each state transposed the directive into its own law, so the channel is national even though the thirty-day trigger is not.