Extension of the period for non - imposition of administrative fines for overdue submission of DAC6

Updated: Jun 10

The Tax Department (TD) has announced that the date for the non-imposition of administrative fines for overdue submission of DAC6 information have been extended from 30 June 2021 to 30 September 2021, in the following cases:

• Reportable cross-border arrangements (RCBAs) that were implemented between 25 June 2018 and 30 June 2020 and had to be submitted by 28 February 2021;

• RCBAs held between 1 July 2020 and 31 December 2020 and had to be submitted by 31 January 2021;

• RCBAs held between 1 January 2021 and 31 August 2021, that had to be submitted within 30 days from the date they were made available for implementation or were ready for implementation or the first step in the implementation was made, whichever occurred first;

• RCBAs for which secondary intermediaries provided aid, assistance or advice, between 1 January 2021 and 31 August 2021 and had to submit information within 30 days beginning on the day after they provided aid, assistance or advice.

In addition, the announcement states that the sample XML file that is available on the TD’s website has been revised, with the addition of fields for information on the associated enterprises to the relevant taxpayer. This is in accordance with Article 7D(13)(a) of the Administrative Cooperation in the Field of Taxation Law 205(I)/2012, which states that the information submitted with respect to a RCBA should also include information for the associated enterprises to the relevant taxpayer.


This article and its publication are intended to provide a brief introduction and act as a general guide on the subject at hand . This is provided for information purposes only and cannot be utilized as a substitute for professional advice. This document does not represent a legal opinion and each natural or legal person seeking to employ the provisions of the document should seek independent advice based on the particulars of its case. No responsibility is accepted by the author or the publishers for any loss suffered from acting or refraining from acting based on the contents of this publication.

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