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.