DAC 6: Luxembourg Is Extending Reporting Deadline/Situation for Germany Remains Uncertain
On 27 July 2020, Luxembourg has published a law amending the reporting deadline regarding cross-border tax arrangements in Mémorial A No. 638.
Therefore, the following reporting deadlines apply in Luxembourg:
If the first step of an arrangement was implemented between 25 June 2018 and 30 June 2020, reporting can be made by 28 February 2021.
If the first step of an arrangement is implemented between 1 July 2020 and 31 December 2020, the 30-day reporting period will start on 1 January 2021.
Information on marketable cross-border tax arrangements must be submitted for the first time by 30 April 2021.
The anticipated BMF letter, following Mr. Scholz’s statement on the rejection of a deadline extension by the German legislator, has so far not been published. Therefore, the deadlines set forth in Section 138f.(2) of the German Tax Code continue to apply in Germany:
If the first step was implemented between 25 June 2018 and 30 June 2020, reporting must be made by 31 August 2020.
For arrangements from 1 July 2020 onwards, the 30-day period has thus already begun.
We will continue to provide information about the latest developments.