Act 10/2020, of December 29, modifies the Spanish General Tax Act, transposing the new obligation to report potentially aggressive tax planning arrangements provided under Council Directive (EU) 2018/822 of May 25,2018 (“DAC 6”)
> New obligations to report potentially aggressive crossborder tax planning arrangements fall on intermediaries and other relevant taxpayers.
> Arrangements subject to reporting must meet certain hallmarks specified in the Directive.
> New reporting obligation to update information on marketable crossborder arrangements.
> New obligation for taxpayers to file reports on the use in Spain of crossborder arrangements that should have been previously reported.
> Transitional regime to report crossborder arrangements where the first step of which was implemented between June 25,2018, and June 30, 2020, and arrangements where the reporting requirement is triggered from July 1, 2020.
> Specific penalty regime.