DAC6 & Proposed Unshell Directive at the STEP Israel Conference
At the Annual STEP Israel Conference, I have been the moderator for a panel, where we discussed DAC6 (Directive of Administrative Cooperation volume 6) and the proposed Unshell Directive. DAC6 is an additional tax transparency initiative implemented as EU Directive in 2018, which calls for a mandatory disclosure of reportable cross-border tax arrangements by “intermediaries”, so called “gate-keepers” including law firms, accountants, and auditors. With “Unshell” a proposed EU-Directive, published December 2021, the EU- Commission wants to tackle the use of “Shell-entities”, so called letter-box entities, “Briefkastengesellschaften” in the European Union. In the proposed draft the European Commission lays down a “new substance test” subject to exchange of information for entities in the European Union. Lawyers from France, Italy and Germany discussed these two initiatives with me.
