Mandatory Disclosure Rules in the EU. The European Union (EU) has introduced the MDR Directive (also known as DAC-6) to increase fiscal transparency concerning aggressive cross-border tax planning.

To assist our clients in being compliant with the MDR, we have developed tools and policies to identify and report the MDR cross-border arrangements.

Our in–house tax experts, together with respective account managers in our EU-based offices, review all the transaction/ arrangements for client entities in real-time to determine the MDR reportable arrangements. If reportable, we will undertake the necessary MDR reporting within the statutory timeline of 30 days. We work together with other intermediaries to mitigate any overlap of MDR compliance.

Our MDR services include:

Reporting & maintenance services
  • A review of EU cross-border arrangements in real-time.
  • Liaison and coordinate with client and the other service providers involved in the arrangement.
  • If reportable, conclude with other intermediaries who will undertake the MDR reporting.
  • File the MDR reporting with the tax authorities within statutory timelines, as and where applicable.
  • Maintenance of adequate MDR analysis, reporting, and documentation.
  • Generate periodic MDR summary reports for all reportable as well as non-reportable cross-border arrangements for the documentation purpose.
Preferred intermediary services
Effective dates and deadlines

The MDR Directive entered into force on June 25, 2018, and was implemented in most EU countries by early 2021. The provisions applied retroactively for all reportable arrangements starting June 25, 2018.

  • All the reportable arrangements where the first step of implementation was taken (or significantly amended) between June 25, 2018, and December 31, 2020, were required to be reported by the intermediary by February 28, 2021.
  • From January 1, 2021, and onwards the reportable arrangements must be disclosed within 30 days from the day that the arrangement was made available or ready for implementation, or when the first step was made.

Non-compliance with the MDR may trigger substantial penalties as established by each jurisdiction, which can go up to several hundred thousand euros.

For more details on MDR, the hallmarks, and the main benefit test, read our MDR Memo and the MDR Flowchart.

For more information on how to respond to the MDR Directive and taking advantage of Amicorp’s services, please contact your Amicorp Account Manager, Sales Manager or your nearest Amicorp office.

Our professionals

Eric Boes, Global Head – Regulatory Reporting and Tax Compliance Services
Shweta Aggarwal - Assistant Manager