DAC6 Notification Requirements 

Legislative Decree no. 100/2020 transposes the so-called DAC 6 Directive (no. 2018/822) relating to the mandatory automatic exchange of
information relating to cross-border aggressive tax planning mechanisms.
These are tax evasion- and abuse-prevention provisions which provide for certain disclosure obligations to tax authorities, if particular crossborder tax planning mechanisms are implemented which, in addition to involving economic operators resident in Italy, also involve foreign entities or foreign permanent establishments.
Failure to provide the information in question is punished by administrative penalties ranging from 2,000.00 to 21,000.00 Euro, increased by half.
Notification is required if 4 preconditions are in place; the first two are mandatory and the remaining two are to be assessed according to
specific cases.
They are summarized in the table below.

It is appropriate to point out that, among the various Hallmarks identified by the DAC 6 regulations, which are potentially susceptible of generating tax circumvention and/or evasion, there are also some cases related to the Transfer Pricing discipline (Group E Hallmark).