Blika has now implemented DAC 6 solutions in several countries and has thus gained many valuable insights that may be of interest for groups who are currently working with their DAC 6 process. We will share some of our insights below.
Many groups have come to the conclusion that the DAC 6 regulations are quite complex and require deep knowledge of the legislation in order to fully understand it. Furthermore, you may need to collect a lot of information from local sources since all information may not be found centrally. Often local reporters do not have enough tax knowledge to interpret the DAC 6 legislation. This raises the question of how to ensure that you identify and collect arrangements within the rolling 30 day filing deadline.
The approach which works for most groups is to identify the typical arrangements which occur in your group which will be determined when you review all arrangements from June 25, 2018 up until June 30, 2020, which you need to file this summer. When you have identified these arrangements, you can provide them to your local reporters via a system solution and ask them to always report these arrangements for review and possible filing. This will be a very practical approach which will ensure that you can comply with the legislation.
Very few groups see the need for a checklist or questionnaire since it will be difficult to get local reporters to take the time to fill in a time-consuming questionnaire every second week or so for every arrangement they would like to assess. In addition, the legislation is complex and it may be difficult to assess if an arrangement should be filed using a simple questionnaire. A practical approach is often preferred. Especially since the group will gain more knowledge over time of the arrangements that occur within the group and thus you will need to spend less time on assessments.
Our experience from working with implementations is that the key to success relies on helping the reporters as much as possible and making the reporting simple to ensure that all arrangements are caught. This is done by tailoring the solution to your specific needs and providing typical arrangements that should always be reported.
If you would like to know more on how we could support your DAC 6 process, please do not hesitate to get in touch. Contact firstname.lastname@example.org to set up a meeting to discuss how we at Blika can support your organisation.