As {News-2020-07-07/P/3-previously reported}, Germany decided to the surprise of many not to avail of the option to defer DAC6 reporting by up to 6 months. The optional nature of the possibility to defer DAC6 reporting is bound to create asymmetries with various consequences within the EU, and the Dutch tax administration posted a warning to Dutch intermediaries in relation to one such potential consequence in Germany. Primary reporting under DAC6 lies with the intermediary and is shifted to the Relevant Taxpayer (RTP) in a number of situations, including in cases where the intermediary is prevented from reporting due to legal...