Hot topics in global tax


Sweden postpones deadlines for reporting reportable cross-border arrangements

Tax Alert

Published: 2020-07-01

On 3 June, the Swedish parliament voted through the government's proposal for the implementation of DAC 6. On 24 June, the Council of the European Union adopted an amending directive for DAC 6 which allows Member States to adopt new dates for initial reporting to the authorities. Sweden chooses to use this option and postpones the deadlines by six months.

Implementation of DAC 6

On 25 June 2018, Council Directive (EU) 2018/822, also known as DAC 6, entered into force. The Directive introduces common EU rules on data obligations relating to so called reportable cross-border arrangements and the automatic exchange of information on these arrangements between the competent authorities of the Member States and to the European Commission. The aim of the Directive is to combat potentially aggressive tax planning by increasing transparency and changing behavior in the longer term.

At the end of January 2020, the Swedish government submitted a proposal for the implementation of the Directive. The proposal was voted through by parliament on 3 June 2020. 

On 24 June 2020, the Council of the European Union adopted an amending directive for DAC 6, which requires Member States to implement DAC 6 so that national law continues to enter into force on 1 July 2020, the option to postponing the deadline for reporting to the authorities by six months for advisers and, where applicable, relevant tax payers. Sweden has chosen to use the option of deferring the deadlines as follows:


Previous deadline

New deadline

Arrangements 25 June 2018 - 30 June 2020


31 August 2020

28 February 2021

Arrangements 1 July 2020 - 31 December 2020

Within 30 days

Within 30 days from 1 January 2021

Arrangements 1 January 2021 - going forward

Within 30 days

Within 30 days

The new rules came into force 1 July, which means that reporting fees can be imposed in case of lack of reporting of such arrangements that are met by Swedish law from 1 July but not reported according to the new, postponed, deadline.

Deloitte's comment

It is welcome that Sweden has chosen to use the option of postponing the deadlines for reporting. However, it is important to take into account that Swedish rules entered into force 1 July, and, also, that DAC 6 entails reporting obligations for retroactive arrangements from 25 June 2018 through 30 June 2020.

Since it is up to each Member State to decide on the possible implementation of new dates for initial reporting to the authorities, it is important to also follow developments in other EU countries. Our hope is a uniform application within the EU, but there is already evidence that some countries will use the option of postponing the deadlines for initial reporting, while others choose not to do so.

Deloitte continues to follow developments. If you have questions about how we work with engagements that entail a reporting obligation or how you, as a taxpayer, should relate to the rules, you are welcome to contact your advisor or Frida Haglund, Lars Franck, Jens Gullfeldt, Magnus Larsson or Frida Borg.

Contact us

Frida Haglund

Lars Franck

Jens Gullfeldt

Magnus Larsson

Frida Borg

Hade du nytta av den här informationen?