The European Commission has proposed a comprehensive recast of the Directive on Administrative Cooperation in Taxation (DAC), marking the first major review of the framework since its introduction. While the proposal seeks to simplify compliance and reduce administrative burdens, particularly under DAC6, an important question remains: are the proposed reforms sufficient to address the shortcomings that businesses and advisers have experienced over the past eight years?
In this article, Tax Partner, Oliver R. Hoor, and Chief Knowledge Officer, Marie Bentley, examine the European Commission's proposed DAC Recast, highlighting the key simplification measures, their implications for taxpayers and intermediaries, and the areas where the proposal still falls short. From the recalibration of DAC6 reporting obligations to the introduction of new substance criteria and the interaction with Pillar Two, our experts provide a practical and critical assessment of what the reforms could mean for cross-border tax transparency in the years ahead.