EU Council Directive 2018/822/EU issued on the 25th of May 2018 covering the mandatory automatic exchange of information in the field of taxation in relation to reportable cross-border arrangements, referred to as  “DAC 6”, requires intermediaries and, in some cases, taxpayers to report to the tax authorities all cross-border arrangements that satisfy specific hallmarks which are deemed to be characteristic of potentially harmful tax practices. 

On 24th June 2020, in order to cater for the disruptions caused by the Covid pandemic, the European Parliament agreed to provide an optional deferral to Member States in respect of the deadlines laid down in the directive.

In light of this, the Malta Office of the Commissioner for Revenue (“CfR”) announced that the DAC 6 reporting deadlines would be extended by six months. By means of the above deferral, the first reporting deadline in relation to reportable cross border arrangements the first step of which took place between 25 June 2018 and 30 June 2020 will be 28 February 2021 and reportable cross-border arrangements whose obligation to report arose between 1 July 2020 and 31 December 2020 should be reported within the 30 day timeframe starting from 1 January 2021.

The CfR will be providing reporting systems and guidance within the coming months to assist intermediaries and taxpayers with their reporting obligations.