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Reading time: 4 minutes | June 25, 2020 | by Hank Moonen

Introduction – the “pain.”

At TaxModel, we try to think about almost anything that can help you with your DAC6 compliance journey.

 

In addition to being able to properly assess, record, and (timely) report, an equally great concern of intermediaries or large multinationals is how to ensure that DAC6 compliance is anchored in daily advisory practice. Failure to report arrangements in time and incorrectly can lead to substantial fines or even a prison sentence. This is separate from any reputational damage.

 

Although all prospects and clients love our DAC6pro solution, they asked whether we could also help them with features that help them, anchor, enforce, and monitor their employees’ actual compliance behavior. These intermediaries may not be as blessed as big four companies that have super fancy internal controls and workflow management systems in place.

 

DAC6 Enforce – general

It will be extra difficult for intermediaries with not-so-deep pockets to change the compliance behavior in people. TaxModel, therefore, decided to put in its roadmap a new add-on feature for DAC6pro that can provide overview, insight, and guidance in the compliance by intermediary employees with regard to DAC6 compliance. We will start building this on the 1st of July, to be MVP ready on the 31st of August 2020.

DAC6 Enforce – functionalities

DAC6 Enforce will be used for asking – based on regular intervals – (selected) employees for information about existing and emerging advice processes (arrangements) that may fall within the scope of DAC6.

Regularly asking users for such information will remind the user, invite and activate them to include DAC6 checks as standard in advisory processes. Also, based on this information, behavior can be identified, and guidance can be given. It also provides an audit trail to internal and external stakeholders that you have implemented its checks and balances for DAC6 compliance.

 

Below we shortly outline the relevant features.

 

Admin environment

First, an admin environment must be set up to define who should participate in the mailing questionnaire.

 

The mailing administrator (e.g., the compliance officer) has the option to do this in bulk or per individual user. If the mailing administrator chooses to do this in bulk, multiple users can be selected and an interval (defined in days) and the start date set. The mailing administrator can also change this per user.

 

The mailing administrator selects the user from the list and tells them to create the mailing questionnaire and sets the interval (defined in days) and the start date.

 

Questionnaire

DAC6 Enforce add-on will offer a pre-defined mailing questionnaire (this can be modified/expanded to needs) that the user will prepare periodically. With these pre-defined questionnaires, you will gain insight into the following questions:

 

  • Which users confirm that they have made all the right arrangements?
  • Which users do not confirm that they have made all the right arrangements?
  • Which users respond to the questionnaire?
  • How many users indicate that they report all necessary arrangements?
  • How many users indicate that they do not report all necessary arrangements?
  • How many users do not respond to the questionnaire?
  • What is the trend in the confirmation if they report all the necessary arrangements or not?
  • What is the trend in the number of users who do not respond to the questionnaire?

 

Trends & analytics

Trends and behaviors of DAC6pro users can be identified by means of additional data analysis:

 

  • How many arrangements did a person work on in a given period?
  • What amounts?
  • How much time does an assessment take?
  • Etc.

 

All this can be done at the office level or the employee level.

 

DAC6 Enforce – happy path

The flow of DAC6 Enforce module will be as follows:

 

  • The user receives an e-mail from DAC6pro asking whether the user has reported all relevant arrangements in DAC6pro
  • The user can select his answer directly in the mail
  • Clicking the answer authorizes the user to be the addressee of the question and saves the answer
  • The user receives a thank-you e-mail or confirmation and, depending on his choice, he/she is given the opportunity to create a new arrangement in DAC6pro, or the process can be closed (close mail)
  • All answers from the questionnaire will be logged and disclosed in beautiful dashboards (and we will be adding dashboards based on your feedback and/or requests)

 

DAC6 Enforce – pricing

We think that this feature will be most relevant for midsize to large intermediaries and larger multinationals. We will be offering the add-on for € 1,475 per multinational per annum or € 1,475 per intermediary country, per annum.

 

We hope you like this option and would be honored if we could sign you up!

 

You can find us here: https://tax-model.com/solutions/dac6pro.