Field help: (2019) Cross-border tax planning

If you have developed a cross-border tax planning yourself, you are obliged to report this tax planning to the tax office. This also applies if the tax planning was drawn up by a third party (intermediary) and this third party is subject to the legal obligation of secrecy and you have not released the intermediary from the obligation of secrecy.

The obligation to report plans applies primarily to the intermediary (mediator) of the plan. An intermediary is defined as someone who markets a tax planning, designs it for third parties, organises it or makes it available for use or manages its implementation by third parties. Furthermore, the intermediary must be a tax resident in an EU member state or provide its services through a permanent business establishment located in an EU member state.