CfR issues guidance on annual DAC6 notification for non-disclosing intermediaries

Deloitte Malta Tax Alert

16 November 2021

The Commissioner for Revenue (‘CfR’) has made available the annual notification (‘Annual Notification’) to be submitted by non-disclosing intermediaries for Reportable Cross-Border Arrangements in terms of regulation 13(7)(e) of the Cooperation with Other Jurisdictions on Tax Matters Regulations (Subsidiary Legislation 123.127 of the Laws of Malta).

The CfR has notified non-disclosing intermediaries that the Annual Notification must be submitted by 28 February 2022 for cross-border arrangements where the trigger point for the reporting obligation took place up to 31 December 2021. Furthermore, the deadline for submitting the Annual Notification in subsequent years shall be the end of February.

The CfR has also made available the Annual Notification document which must be completed, signed and submitted in Excel format as an email attachment to

The Annual Notification document requires a non-disclosing intermediary to provide information on the name, address, tax identification number and country of residence of the person with respect to whom the reporting obligation was waived. Details of the arrangement must also be provided, and these include, inter alia, the date when the reporting obligation was triggered, the date when the other intermediary or the relevant taxpayer was notified, the concerned DAC6 hallmark and the Arrangement ID.

The Annual Notification and relevant DAC6 guidance have been made available through the CfR website.

More information on DAC6 may be found here.

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