Over recent years, increasingly more initiatives concerning the automatic exchange of information have been implemented, in order to react to aggressive tax planning phenomena.
To further strengthen means available to Tax Authorities to prevent and discourage aggressive tax planning, Directive (EU) 2018/822 (hereinafter the «Directive»), which includes further adjustments to directive no. 2011/16/EU, introduced the automatic exchange of information in relation to the so-called “cross-border arrangements”.
Specifically, the Directive obliges intermediaries and, in some cases, taxpayers, to inform Tax Authorities on certain schemes, stipulations, etc. that could imply the presence of an aggressive tax planning.
By Lorenzo Carminati - Principal di Bernoni Grant Thornton
Over recent years, increasingly more initiatives concerning the automatic exchange of information have been implemented in order to react to aggressive tax planning phenomena. In the EU, many directives have progressively extended the perimeter of the automatic exchange of information [...]
Expert's opinion - DAC6 and disclosure obligations for financial intermediaries
By Gianni Bitetti - Partner di Bernoni Grant Thornton
With Directive 2018/822/EU (hereinafter, the “Directive” or “DAC6”) of 25 May 2018, which modified previous Directive 2011/16/EU, the Council of the European Union introduced specific provisions on the automatic exchange of information [...]
By Paolo Besio - Partner di Bernoni Grant Thornton
Among the hallmarks indicated in Annex 1 to Legislative Decree n. 100, i.e. among the indicators of a possible tax avoidance intent, those listed under letter E are relevant to transfer pricing. For the purposes of the regulation under analysis [...]