The Cooperation with Other Jurisdictions on Tax Matters Regulations (S.L. 123.127), inter alia, transpose the provisions of Council Directive (EU) 2018/822 of 25 May 2018 amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation in relation to reportable cross-border arrangements (“DAC6”). They establish an obligation incumbent upon so-called ‘intermediaries’ to file information with the Commissioner for Revenue on ‘reportable cross-border arrangements’ (as defined), that is within their knowledge, possession or control.

The members of the Direct Tax Committee and the Council of the Malta Institute of Taxation discussed the Regulations at a think-tank session earlier this year, after which a Position Paper was drawn up, setting out the views considered and conclusions drawn during the session and, in turn, the resulting views of the MIT on the specific issues addressed...