Strategizing Multinational Tax Risks

The final legislation was recently enacted, although silent on the optional 6-month DAC6 deferral period.  Additionally, some highlights include:

• Domestic arrangements are included, withThe guidance VAT
• Additional hallmarks from draft legislation have been removed
• Hallmark E1, unilateral safe harbors, does not include those specified in the OECD guidelines
• Specified penalty amounts are provided

The DACD6 guidelines for Member States are emerging rapidly, and taxpayers/intermediaries will need to react accordingly.

https://www.ey.com/en_gl/tax-alerts/portugal-publishes-final-legislation-to-implement-mandatory-disclosure-rules