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Local variations in DAC 6 implementation

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The local implementation of the EU’s ‘DAC 6’ Directive by EU member states differs in several key aspects, including: the operation of legal and professional privilege; the application of the tax main benefit test; inclusion of domestic transactions and additional taxes in scope; and the level and type of penalties awarded. These differences are compounded by differing interpretations of the basic DAC 6 provisions between member states. Taxpayers and intermediaries alike therefore need to be aware of how these differences will practically impact the disclosure report and how they meet their DAC 6 reporting requirements.

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