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Taxation in relation to notifiable cross-border arrangements

Council Directive (EU) 2018/822 of 25 May 2018 (amending Directive 2011/16/EU as regards the compulsory automatic exchange of information in the field of taxation in relation to notifiable cross-border arrangements), so-called DAC6, imposes a disclosure burden on intermediaries and taxpayers in case of aggressive “cross-border arrangements”.

In Italy, the regulation has been implemented by Legislative Decree 100/2020.

On 10 February 2011, the Italian Revenue Agency published the Circular 2/E/2021 on DAC 6 disclosures, which incorporated some of the comments made by the industry.

We would like to remind the first deadline, on which the circular affects by providing that the communications due on 1 February 2021 may be sent, without application of penalties, by 1 March 2021