On January 9, 2020, the Romanian Finance Ministry published a draft Law to transpose the EU Directive concerning reporting of cross-border arrangements (DAC6) into Romanian domestic tax law.
The definitions of “cross-border arrangement,” “intermediary,” and “relevant taxpayer” stipulated in the draft Law are broadly in line with the Directive. Intermediaries are exempt from the reporting requirement in situations where professional secrecy privilege applies.
The reporting triggers for relevant taxpayers and intermediaries are broadly in line with the Directive.
The draft Law would enter into force on July 1, 2020. However, where the first step of a reportable arrangement is implemented on or after June 25, 2018, and prior to July 1, 2020, the required information would need to be submitted by August 31, 2020.
Non-compliance with the reporting obligation would attract a fine of up to RON 100,000.
See Draft Law