OBLIGATIONS FOR FINANCIAL INTERMEDIARIES
DAC6 requires intermediaries to communicate to the financial administration of their Member State the “cross-border mechanisms” subject to notification; identified based on specific distinctive elements called hallmarks and listed in Annex IV of the Directive.
In Italy, the report must be made to the Revenue Agency (Agenzia delle Entrate).
HOW TO TACKLE DAC6
Compliance with DAC6 requires the recipient to establish a system of controls for the detection of transactions which on the basis of specific characteristics (hallmarks) may be subject to reporting to the Revenue Agency.
The approach to compliance can be achieved through the following steps:
- Assessment of the financial intermediary’s structural set-up and potential risk
- Interception and knowledge of the transaction and the subjects involved
- Risk attribution and identification of reportable DAC6 transactions
- Reporting of reportable transactions to the Revenue Agency
The collaboration between JS and Revise helps the intermediary in the design, implementation and execution of the process phases.