The sixth amendment of the Directive on administrative cooperation has just been adopted by Council, on 22 March. Earlier drafts of DAC 7 have received certain attention mostly for the new regime of documentation and reporting obligations imposed upon digital platforms. However, the new Directive also features numerous other important amendments, notably a clarification of ‘foreseeable relevance’ as a precondition for EoI, a new legal basis for EoI group requests, an extension of mandatory EoI to royalties, and a new legal framework for joint audits. In this contribution we focus on the latter development and we discuss some key clarifications and novelties to be found in the new Art. 12a DAC regarding joint audits.
Source Kluwer International Tax Blog
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