The law transposing Council Directive (EU) 2018/822 of May 25, 2018 amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation in relation to reportable cross-border arrangements (known as DAC 6) was published in the Official State Gazette on December 30, 2020. For now, however, the dates when it will be necessary to begin to make the relevant reporting are not known.
On December 18, 2020, the Organization for Economic Cooperation and Development (OECD) published guidance (access here) to clarify and illustrate the practical application of the arm’s length principle in controlled transactions affected by the COVID-19 crisis. In light of the contents of the guidance, taxpayers should analyze the effects of the pandemic on their transfer pricing policies, adjust their economic analyses, review their intragroup agreements and verify whether there will be any substantial change in their advance pricing arrangements.