Spain has published the Law transposing Directive DAC 6, which will come into force on 31 December. However, in line with EU legislation, it provides for a transitional regime for arrangements for which the first stage of implementation took place between 25 June 2018 and 30 June 2020. In addition, it also applies to cross-border arrangements that have been subject to the obligation (not just to implementation) from 1 July 2020.

Implementing legislation is yet to be published, but it is expected soon, when a number of administrative reports on these rules are finalized.