Council Directive (EU) 2018/822 of 25 May 2018 has been published in the Official Journal of the EU. The Directive provides for the reporting of potentially aggressive cross-border tax-planning arrangements.
The reporting obligation generally applies to intermediaries that design, market, organize, or manage the implementation of a reportable cross-border arrangement, such as accountants, tax advisors, notaries, banks, etc. However, the reporting obligation may be shifted to a taxpayer in …