In the EU, BEPS Action 12 was adressed by amending the EU Directive on Administrative Cooperation 2011/16/EU through the so-called DAC6 Directive ((EU) 2018/822). This was implemented in Germany by law on December 21, 2019, with effect from January 1, 2020 (see §§ 138d – 138k of the german fiscal code). This introduced an obligation to report cross-border tax arrangements and an automatic exchange of information between EU member states regarding these arrangements.