On 26 February 2021, the Cypriot Tax Department (CTD) issued an announcement which provides that no imposition of administrative fines for submission will apply until the 30th of June 2021, with respect to information on reportable cross-border tax arrangements under the European Union (EU) Directive on the mandatory disclosure and exchange of information (referred to as DAC6 or the Directive).

Notwithstanding the CTD's previous announcement regarding the extension of DAC6 reporting deadlines until 31st March 2021, the Tax Department has also announced their intention not to impose administrative fines for overdue submission of information under DAC6 until 30 June 2021, for the following cases:

  • Reportable cross-border arrangements that have been made (i.e., of which the first step of implementation has taken place) between 25 June 2018 and 30 June 2020 (i.e., within the transitional period of the Directive) and had to be submitted by 28 February 2021.
  • Reportable cross-border arrangements that have been made (i.e., that were made available for implementation or were ready for implementation or the first step in the implementation has been made or for which aid, assistance or advice has been provided by a secondary intermediary) between 1 July 2020 and 31 December 2020 (i.e., within the six-month deferral period of the Directive) and had to be submitted by 31 January 2021.
  • Reportable cross-border arrangements made or to be made between 1 January 2021 and 31 May 2021 (i.e., within the normal application period of the Directive) that had to be submitted within 30 days beginning on the day after they were/will be made available for implementation or were/will be ready for implementation or when the first step in the implementation has been/will be made, whichever occurred/will occur first.
  • Reportable cross-border arrangements for which secondary intermediaries provided/will provide aid, assistance or advice, between 1 January 2021 and 31 May 2021 (i.e., within the normal application period of the Directive), and had to submit information within 30 days beginning on the day after they provided/will provide aid, assistance or advice.

A detailed alert will follow when the DAC6 is enacted into final law.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.