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Submission periods

Disclosure of certain cross-border tax planning arrangements

  1. General deadline for mechanisms arising on or after 14 April 2021.

    30 calendar days after the reporting obligation arises, which shall occur in any of the following circumstances:

    1. The day after a cross-border mechanism subject to disclosure is made available for execution.

    2. The day after the day on which a cross-border mechanism subject to disclosure becomes enforceable.

    3. The time at which the first phase of implementation of the cross-border mechanism subject to disclosure has taken place.

    4. For intermediaries who have undertaken to provide aid, assistance or advice, on the day following the day on which they provided, directly or through other persons, the aid, assistance or advice.

    5. If the intermediary is exempted from submitting the tax return because the transfer of information violates the legal system for the duty of professional secrecy, upon receipt of the notification of this circumstance.

  2. Deadlines for mechanisms for which the reporting obligation arose before 14 April 2021.

    • Cross-border mechanisms whose first phase of implementation took place between 25 June 2018 and 30 June 2020: within 30 calendar days from April 14, 2021 (date of entry into force of the Ministerial Order that develops Model 234, 235 and 236).

    • Cross-border mechanisms subject to communication whose obligation has arisen between 1 July 2020 and 13 April 2021: within 30 calendar days from 14 April 2021.