On 25 June 2018, the European Union introduced a mandatory information exchange regime for cross-border arrangements, the so-called European Mandatory Disclosure Rules (“EU MDR”). These rules are included in a directive: the Directive on Administrative Cooperation 6, or “DAC6”.
DAC6 requires involved intermediaries such as ABN AMRO to report potentially tax-aggressive cross-border arrangements to the local tax authorities so that this information can be shared between the tax authorities of the EU Member States. The rules are very broadly defined. This sometimes also requires commercial transactions to be reported that do not result in a tax benefit.