On 13 September 2023, the French tax authorities updated their DAC 6 administrative guidelines to clarify hallmark D.1.b., which relates to the transfer of financial accounts or assets to jurisdictions not bound by the automatic exchange of financial account information. The guidelines provide examples and specify that certain arrangements may not be reportable under DAC 6 if they do not involve the transfer of an account, a financial asset, or a payment that is part of a reportable cross-border arrangement known by the financial institution. The guidelines also highlight that intermediary involvement may shift reporting obligations, but emphasize that disclosure under DAC 6 does not exempt parties from their obligations under other financial regulations.
Source Deloitte
