Communication Manual Automatic Exchange of Tax Arrangements (DAC 6)

Communication Manual
Automatic exchange of tax

arrangements (DAC 6)
Procedure description, responses and business rules
Version: 2.0
Last updated: 01/06/2021
Communication Manual - Automatic exchange of tax
Table of contents
Table of contents ..................................................................................................................................... 2
List of tables .............................................................................................................................................. 4
List of figures ............................................................................................................................................ 4
0. Information about this document ......................................................................................... 5
0.1. Change history ........................................................................................................................................ 5
0.2. Purpose of this document ................................................................................................................10
1. Data content................................................................................................................................ 10
1.1. Terms .......................................................................................................................................................10
1.2. General information ...........................................................................................................................11
1.2.1. File size limit ................................................................................................................................11
1.2.2. Character set and encoding ....................................................................................................11
2. Process description and IDs.................................................................................................. 11
2.1. Legal bases .............................................................................................................................................11
2.2. Simplified description of the procedure ....................................................................................12
2.3. Electronic data transmission ..........................................................................................................12
2.3.1. Individual data transmission via BOP ................................................................................13
2.3.2. XML web upload via BOP ........................................................................................................13
2.3.3. Transmission via the ELMA interface ................................................................................13
2.3.4. Distinction to the XML upload via BOP ..............................................................................14
2.3.5. Responses ......................................................................................................................................14
2.4. Description and meaning of identification numbers ............................................................14
2.4.1. ArrangementID ...........................................................................................................................14
2.4.2. DisclosureID .................................................................................................................................15
2.4.3. RefDisclosureID ..........................................................................................................................15
3. Disclosure types ........................................................................................................................ 15
3.1. Complete disclosure ...........................................................................................................................16
3.1.1. Complete disclosure by an intermediary/relevant taxpayer with a non-EU
intermediary ..................................................................................................................................................16
3.1.2. Complete disclosure by a relevant taxpayer (self-designed arrangement) ........19
3.1.3. Complete disclosure by a relevant taxpayer (Intermediary’s duty of
confidentiality) ..............................................................................................................................................20
3.1.4. Subsequent disclosures of marketable arrangements ................................................22
3.2. Partial disclosure .................................................................................................................................22
Seite 2 von 72
3.3. Follow-on disclosure ..........................................................................................................................25

3.4. Correction of disclosures..................................................................................................................27
3.4.1. Complete disclosure ..................................................................................................................27
3.4.2. Partial disclosure ........................................................................................................................28
3.4.3. Follow-on disclosure.................................................................................................................28
3.4.4. Limitation for the correction of initial disclosures of a marketable arrangement
28
3.5. Type of obliged entity ........................................................................................................................29
3.6. Deletion ...................................................................................................................................................29
3.6.1. Technical deletion ......................................................................................................................29
3.6.2. GDPR deletion ..............................................................................................................................30
3.7. General requirements for data transmission ...........................................................................30
3.7.1. Arrangement Chart ....................................................................................................................30
3.7.1.1. Multiple top elements......................................................................................................32
3.7.2. Initial disclosures of a marketable arrangement...........................................................33
3.7.3. Marketable arrangements ......................................................................................................33
3.7.3.2. Coherence check for subsequent disclosures ........................................................34
3.7.4. Language requirements ...........................................................................................................34
3.7.5. Input related to tax identification data ..............................................................................35
3.7.6. Entries regarding the hallmarks ..........................................................................................37
3.7.7. Name of the arrangement .......................................................................................................37
3.7.8. Implementation date ................................................................................................................37
3.7.9. Indication of national provision ...........................................................................................37
3.7.10. Input restriction for certain mandatory fields ...........................................................38
3.7.11. Input restrictions for enumeration types ....................................................................38
3.7.12. „Unknown„ specification (unknown attribute) .........................................................39
4. Notes and error messages ..................................................................................................... 41
4.1. Errors in a disclosure .........................................................................................................................43
4.2. Delivery-related notes .......................................................................................................................68
5. Annexes ........................................................................................................................................ 71
5.1. Glossary ...................................................................................................................................................71
5.2. Data set description ............................................................................................................................71
5.3. Example xml files .................................................................................................................................71
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List of tables
Table 1: Prohibited characters .........................................................................................................................11
Table 2: Mandatory fields for a complete disclosure by an intermediary/relevant taxpayer
with a non-EU intermediary ..............................................................................................................................18
Table 3: Optional fields for a complete disclosure by an intermediary/relevant taxpayer with
a non-EU intermediary ........................................................................................................................................18
Table 4: Mandatory fields for a complete disclosure by a user (self-designed arrangement)
.......................................................................................................................................................................................20
Table 5: Optional fields for a complete disclosure by a relevant taxpayer (self-designed
arrangement)...........................................................................................................................................................20
Table 6: Mandatory fields for a complete disclosure by a relevant taxpayer (Intermediary's
duty of confidentiality) ........................................................................................................................................21
Table 7: Optional fields for a complete disclosure by a relevant taxpayer (Intermediary's
duty of confidentiality) ........................................................................................................................................22
Table 8: Mandatory fields for partial disclosures by an intermediary .............................................24
Table 9: Optional fields for partial disclosures by an intermediary ..................................................24
Table 10: Prohibited data for partial disclosures .....................................................................................25
Table 11: Mandatory fields for follow-on disclosures from a relevant taxpayer
(Intermediary's duty of confidentiality) .......................................................................................................26
Table 12: Optional fields for follow-on disclosures (Intermediary's duty of confidentiality) 26
Table 13: Prohibited fields for follow-on disclosures from a relevant taxpayer
(Intermediary's duty of confidentiality).......................................................................................................27
Table 14: Type of obliged entity ......................................................................................................................29
Table 15: Schema for German tax numbers ................................................................................................36
Table 16: unknown attribute ............................................................................................................................41
Table 17: Structure of error/message codes ..............................................................................................43
Table 18: General errors .....................................................................................................................................68
Table 19: Messages ...............................................................................................................................................70
List of figures
Figure 1: xml-structure ArrangementChart_Type ....................................................................................31
Figure 2: ArrangementChartRoot_Type with more than one top element .....................................32
Figure 3: Language element ..............................................................................................................................35
Figure 4: XML structure unique constraint .................................................................................................39
Figure 5: example for an invalid specification (enumeration types) ................................................39
Figure 6: Valid example for the unknown attribute in an XML ...........................................................40
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0. Information about this document

Procedure description Automatic exchange of tax arrangements (DAC 6)
Document title Procedure description, responses and business rules
Primary author Federal Central Tax Office (Bundeszentralamt für Steuern - BZSt),
Automatic exchange of tax arrangements (DAC6)
Created on 14/08/2019
Last revised on 01/06/2021
Link Website Federal Central Tax Office

- Automatic exchange of tax arrangements (DAC6) -
communication manual
0.1. Change history
Document XML Date Change

Version Schema
Version
0.1 2.06 (EU) 07/10/2019 Initial creation

0.01 (BZSt)
0.2 3.02 (EU) 26/03/2020 Revision to reflect new scheme and extension
0.06 (BZSt)
0.3 3.02 (EU) 20/04/2020 Deletion of Business Rule [DAC6_E_MES_054] and

addition of Business Rule [DAC6_E_MES_067];
0.06 (BZSt)
adjustments and corrections
1.0 3.02 (EU) 08/05/2020 Publication on the Website of the Federal Central Tax
Office
0.06 (BZSt)
Seite 5 von 72

Version Schema
Version
1.1 3.02 (EU) 29/06/2020  Relocation and concretization of the note

0.06 (BZSt) concerning the update of marketable
Arrangements (§ 138h par. 2 German Fiscal
Code (AO))
 Concretization of chapter 3.7.1. concerning
the Arrangement Chart
 Addition of a table concerning the calculation
of a German Tax Number according to the
standard federal scheme in chapter 3.7.4.
Input related to tax identification data
 Addition of chapter 3.7.6. Disclosure Name
 Addition of chapter 3.7.7. Implementing Date
 Addition of chapter 3.6.1. Technical deletion
 Addition of chapter 3.6.2. GDPR deletion
1.2 3.02 (EU) 31/07/2020  Concretisation concerning ELSTER certificates

0.06 (BZSt)  Extension of explanation concerning the
Arrangement Chart
 Clarification of note code [DAC6_I_MES_003]
 Addition of chapter 3.7.9. Indication of
national provision
 Publication of the English Version on
www.bzst.bund.de
Seite 6 von 72

Version Schema
Version
1.3 3.02 (EU) 08/09/2020  Clarification of mandatory fields in chapter

0.06 (BZSt) 3.1.3.
 Editorial changes in chapter 3.5.
 Addition of chapter 3.7.2. Initial disclosures
of a marketable arrangement
 Addition of chapter Fehler! Verweisquelle
konnte nicht gefunden werden.. Information
on Concerned Member States and Receiving
Countries
 Clarification in chapter 3.7.4. and addition of
a figure
1.4 3.02 (EU) 28/09/2020  Deletion of business rule [DAC6_E_MES_049]

0.06 (BZSt) and correction of business rule
[DAC6_E_MES_059] to allow the
transmission of bespoke arrangement with
the hallmark “DAC6A3”
 Correction of business rule
[DAC6_E_MES_068] due to EU specifications
(see also the list of known errors on the
website of the Federal Central Tax Office)
 Specification to the 2nd case in chapter 3.2.
(partial disclosure)
1.5 3.02 (EU) 12/11/2020  Correction of the text concerning business

0.06 (BZSt) rule [DAC6_E_MES_050]
 Addition of business rule [DAC6_E_MES_054]
for the clarification of business rule
[DAC6_E_MES_050] for follow-on disclosures
1.6 3.02 (EU) 04/12/2020  Change of business rule [DAC6_E_MES_068]

0.06 (BZSt)  Addition in chapter 3.7.9. Indication of
national provision
Seite 7 von 72

Version Schema
Version
1.7 3.02 (EU) 01/04/2021  Addition of chapter 3.1.4. Subsequent

0.06 (BZSt) disclosures of marketable arrangements
 Addition of business rules concerning Brexit,
indication in the element NationalExemption
and enumeration types in chapter 4.1:
[DAC6_E_MES_082], [DAC6_E_MES_083],
[DAC6_E_MES_084] und DAC6_E_MES_085]
1.8 3.02 (EU) 01/06/2021  Clarification in chapter 3.1. Complete

0.06 (BZSt) disclosure
 Clarification in chapter 3.2. Partial disclosure
 Specification in chapter 3.6.1. Technical
deletion
 Clarification of business rule
[DAC6_E_MES_023]
2.0 4.01 (EU) 01/06/2021 Adaptation of the communication manual due to

changes by the EU:
1.07 (BZSt)
 Addition of mandatory fields in chapters
3.1.1., 3.1.2., 3.1.3., 3.2. and 3.3. due to the
new element "MarketableArrangement" and
further adaptations due to the new
“Unknown attribute”
 Addition of chapter 3.4.4 Limitation for the
correction of Initial Disclosures of a
marketable Arrangement
 Addition of chapter 3.7.1.1. Multiple top
elements
 Additions and changes in chapters 3.7.2. and
3.7.3. due to the new element
MarketableArrangement
 Addition of chapter 3.7.3.2 Coherence check
for subsequent disclosures
 Deletion of chapter 3.7.4. Information on
Concerned Member States and Receiving
Countries, as the values for the element
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Version Schema
Version
ReceivingCountries have been restricted and
business rule [DAC6_I_MES_004] has been
adapted
 Addition of chapter 3.7.10. Input restriction
for certain mandatory fields
 Addition of chapter 3.7.11. Input restriction
for enumeration types
 Addition of chapter 3.7.12. „Unknown„
specification (unknown attribute)
 Deletion of business rules
[DAC6_E_MES_041] and [DAC6_E_MES_044],
as they are obsolete due to changes in the
xml-schema
 Addition of business rules
[DAC6_E_MES_078] [DAC6_E_MES_079],
[DAC6_E_MES_080] and [DAC6_E_MES_081]
 Adaption of business rules
[DAC6_E_MES_068], [DAC6_I_MES_003] and
[DAC6_I_MES_005]
Note:
All changes compared to the previous version are indicated by a change marker in the
margin.
Seite 9 von 72
0.2. Purpose of this document

The Communications Manual (CM) contains a description of the procedure as well as the
specific identification numbers (IDs) in use and their meanings for the reporting procedure
related providing notification of cross-border tax arrangements pursuant to sections 138d
et seq. of the German Fiscal Code (Abgabenordnung - AO).
General specifications for the content of data to be transmitted are described in Chapter 1.
Chapter 2 contains a general description of the procedure and a more detailed explanation
of the ArrangementID, DisclosureID and RefDisclosureID.
The specific disclosure types are listed and discussed in more detail in Chapter 3. In
addition, aspects of the business rules are explained in more detail. Data transmitted to the
Federal Central Tax Office cannot be processed if the requirements set out in Chapters 1 to 3
are not complied with. In such cases, the Federal Central Tax Office will respond by sending
relevant error codes and error texts.
Chapter 4 contains a list of error messages and notices including instructions on how to
correct the error. Error codes are documented in brackets “[...]” for the respective
requirement in Chapters 1 to 3.
Chapter 5 lists all the annexes related to this document.
1. Data content
Specific usage requirements are described below from a procedural standpoint. The
requirements apply irrespective of the chosen transmission channel, i.e. irrespective of
whether the data are reported to the Federal Central Tax Office via BZST Online-Portal
(BOP) form or the Electronic Mass Data interface (ELMA).
The Communication Manual does not describe whether a data element is a required or
optional field or whether the data element is repeatable. This information may be found in
the official data set description including the business rules (see Chapter 5) and the XML
scheme.
1.1. Terms
Terms such as “Arrangement”, “UTF-8” and others are used in the General Part of the
Communication Manual. These terms are defined in the glossary (see Chapter 5.1).
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1.2. General information

The requirement that a data element must be specified is considered to be met if an XML
field contains at least one character that is not a whitespace as defined in Java.
If the description specifies that a data element does not apply, this means that the complete
XML field must be omitted.
The sequence in the XML scheme must be strictly adhered to when transmitting via the
ELMA. Variations in the sequence of data elements in relation to the XML scheme result in
the rejection of the disclosure [DAC6_E_MES_002].
1.2.1. File size limit

A restriction on file size applies to data disclosures submitted via ELMA. A disclosure may
not exceed 40 megabytes in size [DAC6_E_MES_001]. Stricter limits apply for disclosures
submitted via the BOP form. They are described in the BOP Form Communication Manual
[Link].
1.2.2. Character set and encoding

Disclosures must be encoded in UTF-8 and transmitted in the String Latin character set
when using the ELMA. The following rules applicable to special characters must be observed
as part of this process.
The following character strings are not allowed for data element content.
Characters Description UTF 8 Code
-- Minus sign Minus sign U+002DU+002D
/* Fraction stroke Asterisk U+002FU+002A
&# Ampersand and pound sign U+0026U+0023

Table 1: Prohibited characters
Non-compliance will result in the rejection of the entire disclosure by the DAC6 system
[DAC6_E_MES_037].
2. Process description and IDs
2.1. Legal bases

Council Directive 2018/822/EU of 25 May 2018 amending Directive 2011/16/EU as regards
mandatory automatic exchange of information in the field of taxation in relation to
Seite 11 von 72
reportable cross-border arrangements, was adopted to enable the exchange and evaluation
of information. National implementation was effected in the form an act introducing the
obligation to report tax arrangements dated 21st December 20191.
The Directive obliges EU Member States to automatically exchange cross-border

arrangement that indicate a potential risk of tax avoidance based on defined hallmarks.
These models must be reported by the intermediaries, or relevant taxpayers under certain
conditions, within 30 days of the reportable event.
Arrangement-related information must be reported, including information on how the tax

arrangement works and the underlying legislation. In addition, relevant taxpayers
associated with the tax arrangements must be reported if available, i.e., relevant taxpayer-
related data.
2.2. Simplified description of the procedure

Since 1st July 2020, intermediaries and, in certain cases, relevant taxpayers will be required
to report cross-border tax arrangements for the first time. The primary reporting obligation
falls on the intermediary. A relevant taxpayer is only affected by the full reporting obligation
if they use an intermediary who is not subject to a reporting obligation in the European
Union or if they designed the arrangement themselves as an in-house arrangement. In cases
where they do not release an intermediary domiciled within the European Union from their
respective confidentiality obligation, the relevant taxpayer it at least partially (in relation to
their personal/relevant taxpayer-related data) subject to a reporting obligation.
2.3. Electronic data transmission

The report is to be transmitted exclusively in electronic form to the Federal Central Tax
Office in accordance with the officially prescribed data set.
The following three communication channels are available for data transmission:
‒ Individual data transmission via the Federal Central Tax Office’s online portal
(BZStOnline-Portal - BOP)
‒ XML web upload via BOP
‒ Electronic mass data interface (ELMA)
1 Federal Gazette 2019 Part I No 52 of 30/12/2019
Seite 12 von 72
2.3.1. Individual data transmission via BOP

Either an active Federal Central Tax Office number (BZ- or BX-Number, for example
assigned for FATCA/CRS/CbCR reports) or a valid Elster certificate (access to Elster
OnlinePortal (EOP); e.g. for tax returns via EOP) is required, for data transmission via BOP.
Additional requirements for reporting via the BOP form is indicated in the BOP Form
Communication Manual [Link].
2.3.2. XML web upload via BOP

An active Federal Central Tax Office number and a valid BOP certificate is required for data
transmission via XML web upload in BOP.
In addition, registration with the relevant department “Automatic exchange of tax-planning

structures (DAC 6)”, along with approval for use of the mass data interface ELMA, must be
completed. The requirements for registration are described in Chapter 2.3.3.
2.3.3. Transmission via the ELMA interface

Registration with the relevant department “Automatic exchange of tax arrangements
(DAC 6)” at the Federal Central Tax Office, as well as approval for use of the ELMA interface,
are required prior to transmitting data via ELMA (or the XML web upload using BOP). The
interface must be activated in BOP. This must be done for each procedure and each portal
account, regardless of whether the discloser has already transmitted data via the EOP, BOP
or the ELMA as part of another procedure.
You will automatically be approved to use the ELMA test environment when you register or
activate your ELMA account.
Registration is only required for the sender of the data, i.e. the discloser ultimately
transmitting the data to the Federal Central Tax Office (external service provider or the
discloser itself) and only needs to be completed once before the initial data transmission.
Portal registration is required prior to initial use of BOP. This step is not necessary if a
discloser already has an active Federal Central Tax Office number and a valid login (BOP
certificate).
If you do not have a valid Federal Central Tax Office number, you must first apply for one
from the relevant department “Automatic exchange of tax arrangements (DAC 6)” at the
Federal Central Tax Office. This is done as part of the registration process for the procedure.
The Federal Central Tax Office does not assign EOP certificate. You may find detailed
information about the registration process on our website [Link].
Seite 13 von 72
2.3.4. Distinction to the XML upload via BOP

DAC6 allows to upload an xml file in BOP to transmit the data to the Federal Central Tax
Office. The structure of the xml file is identical to the one used for transmission via the
ELMA. The response to an xml file uploaded via BOP cannot be retrieved in BOP. As the xml
upload is a transmission via the ELMA the response can only be found in the download
folder and not within BOP. To retrieve the response without using a direct SFTP connection,
BOP offers a download function for the download folder. Please navigate within BOP to
“Forms & Services”/”Submission of mass data (ELMA5)”/”General forms”/”Collection of
ELMA5 protocols”.
The content of the response is similar to those sent via SFTP-connection (see chapter 2.3.5.)
A short user manual can be found in BOP “Forms & Services”/”Submission of mass data
(ELMA5)” after choosing the correct procedure. Please note that an authorization to use the
ELMA is required as well as the integration of the BOP certificate in your browser.
2.3.5. Responses
Following receipt of a report by the Federal Central Tax Office, the sender receives two
additional responses in addition to a response from ELMA:
● The first response states that the disclosure has been received by the system. The
response code [DAC6_I_RES_001] indicates if the disclosure is accepted for
processing and plausibility check.
● The second response (so-called processing log) summarises the result of the
procedural review [DAC6_I_RES_002]. It also contains a list of the individual
messages and errors (see Chapter 4) if any. In addition, the ArrangementID and the
DisclosureID are communicated along with the processing log.
2.4. Description and meaning of identification numbers

The procedure uses several different identification numbers (IDs) to precisely determine
and identify reported tax arrangements and their respective relevant taxpayers.
The various IDs (ArrangementID, DisclosureID and RefDisclosureID) are also required for
the assignment of different disclosures to the respective tax arrangements. The individual
IDs - including the specifications defined for the procedure - are presented and described in
the following chapters.
2.4.1. ArrangementID
The ArrangementID is only issued for the initial disclosure of an arrangement. It is required
to be forwarded to additional, known obliged entities by the first discloser in order to
permit assignment of additional disclosures if applicable.
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The structure of the ArrangementID can be found in the data set description (see Chapter
5.2.). Compliance with the requirements of the data set description is ensured via the
business rules [DAC6_E_MES_016] and [DAC6_E_MES_017].
2.4.2. DisclosureID
A DisclosureID is assigned for each new disclosure (except corrections). It is used to clearly
identify disclosures related to an arrangement.
The inclusion of a DisclosureID is only permitted in the case of corrections (see Chapter 3.4.)
and therefore requires the simultaneous specification of the corresponding ArrangementID
[DAC6_E_MES_004] and [DAC6_E_MES_005].
The structure of the DisclosureID can be found in the data set description (see Chapter 5.2.).
Compliance with the requirements set out in the data set description is ensured via the
business rule [DAC6_E_MES_018].
2.4.3. RefDisclosureID
The RefDisclosureID is used for disclosures in which the relevant taxpayer has not released
the intermediary from their confidentiality obligations. In these cases, the intermediary may
provide arrangement related information (including description of the arrangement) and
the relevant taxpayer may provide the personal information (including identification data)
in each of the respective disclosures.
In order for the two disclosures to be combined by the Federal Central Tax Office, the
relevant taxpayer must provide the ArrangementID provided to them by the intermediary
and the intermediary’s DisclosureID as the RefDisclosureID [DAC6_E_MES_020] and
[DAC6_E_MES_021].
The structure of the RefDisclosureID may be found in the data set description (see Chapter
5.2.). Compliance with the requirements of the data set description are ensured via the
business rule [DAC6_E_MES_019].
3. Disclosure types
A distinction is made between four disclosure types: These types are as follows:
● Complete disclosure
● Partial disclosure
● Follow-on disclosure
● Correction disclosure
The correction function and the requirements for the respective correction messages are
described in more detail in Chapter 3.4.
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Note:
The correction process is to be used for the periodic reports for updates which contains new
reportable information as referred to in § 138h par. 2 AO. Additions of new relevant
taxpayers are not allowed to be transmitted via a correction but need to be transmitted as a
new complete disclosure.
3.1. Complete disclosure

A complete disclosure is deemed to have been made if either the intermediary or the
relevant taxpayer themselves (in the case of non-EU intermediaries, self-designed
arrangements, or where the intermediary has not been released from the confidentiality
obligations) communicates all information (arrangement and relevant taxpayer-related
information) concerning the tax arrangement.
Note:
Only the arrangement related information needs to be transmitted in the initial disclosure in
the case of marketable arrangements [DAC6_E_MES_071] (see also Chapter 3.2.). Relevant
taxpayers may be disclosed in follow-on disclosures as appropriate (subsequent disclosure,
see also chapter 3.1.4.). In this context, please note additional requirements set out in
Chapter 3.7.3.
If the disclosure is processed successfully, the discloser will receive an ArrangementID and a
DisclosureID along with the processing log.
A new complete disclosure with one or more new relevant taxpayers must be submitted,
stating the Arrangement ID, for new relevant taxpayers who are to be added to an already
existing arrangement (subsequent disclosure, see also chapter 3.1.4).
The requirements set out in Chapter 3.5. must be observed for information related to the
reporting obligation (Liability).
The indication of a RefDisclosureID is not permitted for complete disclosures in all cases.
3.1.1. Complete disclosure by an intermediary/relevant taxpayer with a non-EU

intermediary
A complete disclosure by an intermediary/relevant taxpayer with a non-EU intermediary
must contain the following mandatory fields:
Mandatory fields for a complete disclosure by an intermediary/relevant taxpayer with a

non-EU intermediary
MessageRefID
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non-EU intermediary
Timestamp
Identification data concerning the disclosing entity (Disclosing/ID)
Intermediary’s nexus to Germany

(Disclosing/Liability/IntermediaryDiscloser/IntermediaryNexus)
OR
Relevant taxpayer’s nexus to Germany
(Disclosing/Liability/RelevantTaxpayerDiscloser/RelevantTaxpayer
Nexus)
Intermediary’s role
(Disclosing/Liability/IntermediaryDiscloser/Capacity)
(all input values are permitted in this case)
OR
Basis of the disclosing relevant taxpayer’s reporting obligation
(Disclosing/Liability/RelevantTaxpayerDiscloser/Capacity)
(the only permitted input here is “DAC61105” – Non-EU intermediary)
Initial disclosure of a marketable arrangement (InitialDisclosureMA)
Transmission of a marketable arrangement (MarketableArrangement)
(At least one) Relevant taxpayer (RelevantTaxpayers/RelevantTaxpayer)

(not in the case of an initial disclosure concerning a marketable arrangement)
Intermediary (Intermediaries/Intermediary)
Implementation date (DisclosureInformation/ImplementingDate or

DisclosureInformation/ImplementingDate@unknown = "true")
Name of the arrangement (DisclosureInformation/Summary/Disclosure_Name)
Description of the arrangement

(DisclosureInformation/Summary/Disclosure_Description)
Indication of relevant national provisions

(DisclosureInformation/NationalProvision/Text)
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non-EU intermediary
National provision (country of origin)

(DisclosureInformation/NationalProvision/Country)
Economic value of the arrangement (DisclosureInformation/Amount or

DisclosureInformation/Amount@unknown = "true")
Member State(s) concerned (DisclosureInformation/ConcernedMSs)
Main Benefit tax advantage (DisclosureInformation/MainBenefitTest1)
Hallmarks (DisclosureInformation/Hallmarks/ListHallmarks)
Table 2: Mandatory fields for a complete disclosure by an intermediary/relevant taxpayer with a non-EU intermediary
The following optional fields may be included an intermediary’s complete disclosure:
Optional fields for a complete disclosure by an intermediary/relevant taxpayer with a non-

EU intermediary
ArrangementID
(Information only if a further delivery is made for a design that has already been notified)
Language (DAC6Disclosure/Language) (general language setting for a disclosure see

also Chapter 3.7.4.)
Associated enterprises (RelevantTaxpayer/AssociatedEnterprises)

(not in the case of an initial disclosure of a marketable arrangement)
Affected persons (AffectedPersons)

Arrangement status (DisclosureInformation/Reason)
Arrangement Chart (DisclosureInformation/ArrangementChart)

Table 3: Optional fields for a complete disclosure by an intermediary/relevant taxpayer with a non-EU intermediary
Compliance with the requirements of this chapter is ensured via the business rules
[DAC6_E_MES_011, DAC6_E_MES_071].
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3.1.2. Complete disclosure by a relevant taxpayer (self-designed arrangement)

A complete disclosure from a relevant taxpayer must include the following mandatory
fields:
Mandatory fields for a complete disclosure by a relevant taxpayer (self-designed

arrangement)
MessageRefID
Timestamp

Nexus)

(the only permitted input here is “DAC61106” - self-designed arrangement)



Indication of relevant national provision



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Mandatory fields for a complete disclosure by a relevant taxpayer (self-designed

arrangement)
Table 4: Mandatory fields for a complete disclosure by a user (self-designed arrangement)
The following optional fields may be included the relevant taxpayer’s complete disclosure:
Optional fields for a complete deliver by a relevant taxpayer (self-designed arrangement)
ArrangementID
(provided only if a disclosure is being made in relation to a previously-reported arrangement)
Language (DAC6Disclosure/Language)
(general language setting for the disclosure, see also Chapter 3.7.4.)

Table 5: Optional fields for a complete disclosure by a relevant taxpayer (self-designed arrangement)
Compliance with the requirements of this chapter is ensured via the business rule
[DAC6_E_MES_015].
3.1.3. Complete disclosure by a relevant taxpayer (Intermediary’s duty of

confidentiality)
A complete disclosure from a relevant taxpayer must include the following mandatory
fields:
Mandatory fields for a complete disclosure by a relevant taxpayer (Intermediary’s duty of

confidentiality)
MessageRefID
Timestamp
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Mandatory fields for a complete disclosure by a relevant taxpayer (Intermediary’s duty of

confidentiality)
Identification data concerning the obliged entity (Disclosing/ID)

Nexus)

(only the input “DAC61104” - Intermediary’s confidentiality obligation - is permitted here)






Table 6: Mandatory fields for a complete disclosure by a relevant taxpayer (Intermediary's duty of confidentiality)
Seite 21 von 72
The following optional fields may be included the relevant taxpayer’s complete disclosure:
Optional fields for a complete disclosure by a relevant taxpayer (Intermediary’s duty of

confidentiality)
ArrangementID
(provided only if a disclosure is being made in relation to a previously-reported arrangement)
(general language setting for the disclosure, see also Chapter 3.7.4)

Table 7: Optional fields for a complete disclosure by a relevant taxpayer (Intermediary's duty of confidentiality)
[DAC6_E_MES_008].
3.1.4. Subsequent disclosures of marketable arrangements

The disclosures following the initial disclosure of a marketable arrangement, which contain
information on (new) taxpayers, are called subsequent disclosures. In addition to the
information on taxpayers, subsequent disclosures always contain the arrangement-related
information and, if applicable, information on associated enterprises and affected persons.
The specifications for complete disclosure apply (see also chapter 3.1), but an
ArrangementID must always be specified for a subsequent disclosure.
For the first-time indication of taxpayers of a marketable arrangement or for new taxpayers
that are added to an already existing arrangement, a new complete disclosure (subsequent
disclosure) with indication of the ArrangementID with one or more new taxpayers must
be submitted.
3.2. Partial disclosure

A partial disclosure involves cases where
1. an intermediary creates a marketable arrangement, but there is no relevant

taxpayer at that point (an A-ID is not yet available), or
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2. in light of their duty of confidentiality, an intermediary only reports arrangement-

related information (i.e, description of the arrangement) (an A-ID is not yet
available), or
3. a relevant taxpayer of a marketable arrangement does not have an EU-based
intermediary and must therefore file the disclosure or
4. an initial disclosure of a marketable arrangement has to be transmitted.
If processed successfully via the processing log, the disclosure will be assigned an
ArrangementID and a DisclosureID in these cases.
In the second case, the intermediary must then inform the relevant taxpayer of the assigned
ArrangementID and DisclosureID - together with the information that the relevant taxpayer
is obliged to report relevant taxpayer-related data - and provide the relevant taxpayer with
all information needed for reporting. The rules set out in Chapter 3.3. must be observed in
the case of any follow-on disclosure.
Note:
A partial disclosure from an intermediary must include the following mandatory fields:
Mandatory fields for partial disclosures by an intermediary
MessageRefID
Timestamp
Intermediary’s nexus to Germany

(Disclosing/Liability/IntermediaryDiscloser/IntermediaryNexus)
OR
Nexus)
Intermediary’s role
(Disclosing/Liability/IntermediaryDiscloser/Capacity)
OR
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Mandatory fields for partial disclosures by an intermediary

(the only permitted input here is “DAC61105” – Non-EU intermediary)




Economic value of the tax arrangement (DisclosureInformation/Amount or

Table 8: Mandatory fields for partial disclosures by an intermediary
The following optional fields may be included in a partial disclosure from an intermediary:
Optional fields for partial disclosures by an intermediary
(General language setting for the disclosure, see also Chapter 3.7.4)

Table 9: Optional fields for partial disclosures by an intermediary
The following fields are not permitted in the case of a partial disclosure by an intermediary:
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Prohibited fields for partial disclosures by an intermediary
Relevant taxpayer (RelevantTaxpayers/RelevantTaxpayer)

Table 10: Prohibited data for partial disclosures
3.3. Follow-on disclosure

A follow-on disclosure comprises cases in which a relevant taxpayer provides their personal
data related to a previously submitted partial disclosure from an intermediary. This is only
the case if the relevant taxpayer does not release their intermediary from their respective
confidentiality obligation and does not make a complete disclosure (see also Chapter 3.1.3.).
In order for the two disclosures to be merged at the Federal Central Tax Office, the relevant
taxpayer must provide the ArrangementID and the DisclosureID communicated to them by
the intermediary as the RefDisclosureID in the follow-on disclosure.
The person making the disclosure is assigned their own DisclosureID if the follow-on
disclosure is successfully processed.
Note:
A follow-on disclosure from a relevant taxpayer must include the following mandatory
fields:
Mandatory fields for follow-on disclosures from a relevant taxpayer (Intermediary’s duty of
confidentiality)
MessageRefID
Timestamp
ArrangementID
RefDisclosureID
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Mandatory fields for follow-on disclosures from a relevant taxpayer (Intermediary’s duty of
confidentiality)

Nexus)
Basis of the disclosing entity’s reporting obligation

(only the input “DAC61104” - Intermediary’s confidentiality obligation - is permitted here)

Table 11: Mandatory fields for follow-on disclosures from a relevant taxpayer (Intermediary's duty of confidentiality)
The following optional fields can be included in a relevant taxpayer’s follow-on disclosure:
Optional fields for follow-on disclosures from a relevant taxpayer (Intermediary’s duty of
confidentiality)
(General language setting for the disclosure, see also Chapter 3.7.4.)

Table 12: Optional fields for follow-on disclosures (Intermediary's duty of confidentiality)
The following fields are not permitted in a follow-on disclosure from a relevant taxpayer:
Prohibited fields for follow-on disclosures from a relevant taxpayer (Intermediary’s duty of
confidentiality)
Intermediaries
Implementation date (DisclosureInformation/ImplementingDate)
Implementation status (DisclosureInformation/Reason)
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Prohibited fields for follow-on disclosures from a relevant taxpayer (Intermediary’s duty of
confidentiality)
Name and description of the arrangement (DisclosureInformation/Summary)
National provision (DisclosureInformation/NationalProvision)
Economic value of the tax arrangement (DisclosureInformation/Amount)
Hallmarks (DisclosureInformation/Hallmarks)
Table 13: Prohibited fields for follow-on disclosures from a relevant taxpayer (Intermediary's duty of confidentiality)
[DAC6_E_MES_007].
3.4. Correction of disclosures

The original disclosure is not overwritten during the correction process. Instead, new
versions are created upon receipt of a corrected disclosure. The new version of a disclosure
is placed over the previously transmitted disclosure with the corrected information. The
associated IDs (ArrangementID, DisclosureID and RefDisclosureID, if applicable) are used
for purposes of referencing the to-be-corrected disclosure. The timestamp is used to create
the versions.
Note:
Input related to the RefDisclosureID may not be changed in a correction, i.e. the
RefDisclosureID may neither be removed nor added in a correction [DAC6_E_MES_012] and
[DAC6_E_MES_013].
Previously-delivered data must be corrected using the original data submission procedure.
A change between transmission via BOP- form and the ELMA (or the XML-upload in BOP)
may not be made for correction disclosures.
Rules for the correction of the different disclosure types are described below.
3.4.1. Complete disclosure

In order to correct a complete disclosure, and thus to communicate a new version, the entire
disclosure (including the corrected data) including the ArrangementID and the DisclosureID
for the disclosure to be corrected must be transmitted.
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In addition to the provision of the IDs referred to above, the rules regarding mandatory,
optional and prohibited fields, analogous to those contained in Chapter 3.1., remain the
same.
3.4.2. Partial disclosure

In order to correct a partial disclosure, and thus to communicate a new version, the entire
disclosure (including the corrected data) including the ArrangementID and the DisclosureID
for the disclosure to be corrected must be transmitted.
same.
3.4.3. Follow-on disclosure

In order to correct a follow-on disclosure, and thus to communicate a new version, the
entire disclosure (including the corrected data) including the ArrangementID, DisclosureID
and RefDisclosureID for the disclosure to be corrected must be transmitted.
same.
3.4.4. Limitation for the correction of initial disclosures of a marketable

arrangement
Limitations apply for the correction of the initial disclosure of a marketable arrangement.
The following elements must not be changed when sending a correction of an initial
disclosure of a marketable arrangement:
● Language of the disclosure

(DAC6_Arrangement/DAC6Disclosure/Language)
● Name of the arrangement (Disclosure_Name)
● National provision (NationalProvision)
● Main benefit test (MainBenefitTest1)
● Hallmarks (Hallmarks)
Note:
[DAC6_E_MES_075].
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3.5. Type of obliged entity

The following table shows the different types of obliged entities that must be entered into
the reporting obligation (Liability) field along with the associated options for disclosures:
Type of obliged entity Permitted disclosure options
Intermediary Initial disclosures of marketable

arrangements, complete disclosures, partial
(DAC61101 - Development / Sales /
disclosures, corrections
Implementation support)
Intermediary Initial disclosures of marketable

(DAC61102 - Service provider (organising /
management functions))
Relevant taxpayer Follow-on disclosures, complete disclosures,

corrections
(DAC61104 - Intermediary’s duty of
confidentiality)
Relevant taxpayer Initial disclosures of marketable

(DAC61105 - Intermediary from a non-EU
country)
Relevant taxpayer Complete disclosures, corrections

(DAC61106 - Self-designed arrangement)
Table 14: Type of obliged entity
3.6. Deletion
3.6.1. Technical deletion
The deletion of disclosures is organisationally possible only for exceptional cases. . The
exceptional cases are limited to technical aspects or errors, e.g. an erroneous double
delivery of the same cross-border tax arrangement or the specification of an erroneous
ArrangementID or DisclosureID.
Before submitting a request for technical deletion to the BZSt, please first check whether a
correction of the disclosure is possible in accordance with chapter 3.4. Only if a correction of
the disclosure is ruled out can the deletion be considered.
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A written request in via contact form or regular mail2 indicating the DisclosureID, the
MessageRefID and the reason for the technical deletion is required. The Federal Central Tax
Office carries out the deletion of the corresponding disclosure.
Note:
As soon as a correction of disclosures has been made, the technical deletion of both the
original disclosure and the correction disclosure(s) can no longer be carried out. With the
transmission of a correction disclosure, it is to be assumed that a review of the content of
the disclosure(s) has taken place and thus an incorrect transmission of information is
excluded.
This does not affect deletion in accordance with the GDPR pursuant to Chapter 3.6.2.
3.6.2. GDPR deletion

Requests for deletion according to the General Data Protection Regulation (GDPR) can only
be sent by regular mail3. A request must contain both the DisclosureID and the
MessageRefID.
For more information concerning your rights according to the GDPR please consult the
general information upon the implementation of articles 12 to 14 of the GDPR within the tax
administration. This information is available at the following address: [Link].
If your request concerning the GDPR deletion is approved the designated data is deleted by
the Federal Central Tax Office.
3.7. General requirements for data transmission

General requirements will be addressed below. Certain fundamental topics will be described
in greater details along with the respective error messages as part of this discussion.
Additional information on the respective error messages ([DAC6_E_MES_XXX]) may be
found in Chapter 4.1.
3.7.1. Arrangement Chart

This element allows the Arrangement to be depicted as a (logical) structure, in addition to
the narrative description of the arrangement. It allows the depiction of the arrangement and
forms a hierarchical tree structure, which shows each connections and dependencies
between the relevant taxpayers, associated enterprises, affected persons and each obliged
entities. It allows the depiction of each entity or individual involved in the arrangement,
including its ownership (in percent) and the amounts invested with respect to that entity or
2 Bundeszentralamt für Steuern, Meldepflicht Steuergestaltung, An der Küppe 1, 53225 Bonn

3 Bundeszentralamt für Steuern, Meldepflicht Steuergestaltung, An der Küppe 1, 53225 Bonn
Seite 30 von 72
individual for the arrangement. It also allows to further describe the role, capital and cash
flow at each level of the structure.
For the purpose of entering the Arrangement chart information, the starting point is the
Relevant Taxpayer, and its investments and/or ownership in other persons, as the top of the
Arrangement chart. The Arrangement chart can then be extended to sub-levels, as required,
by repeating the Arrangement chart element as so-called “Children”.
Figure 1: xml-structure ArrangementChart_Type
Optional information on the arrangement chart may only be filled in with information on
relevant taxpayers, the disclosing entity, associated enterprises or affected persons that
have already been entered as part of the relevant disclosure. This information must always
be input in exactly the same way. Differences in spelling are not permitted
[DAC6_E_MES_050].
In addition, a person or organisation may not be included in two places within a structure
[DAC6_E_MES_072].
Note:
Entry of the Arrangement Chart is limited to a description of five levels [DAC6_E_MES_069].
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The business rules [DAC6_E_MES_028], [DAC6_E_MES_050], [DAC6_E_MES_054],

[DAC6_E_MES_067] and [DAC6_E_MES_072] are not checked if the Arrangement Chart
exceeds the permitted number of levels.
3.7.1.1. Multiple top elements

The new ArrangementChartRoot_Type has been introduced. It is only used for the first
layer of the ArrangementChart. The difference to the ArrangementChart_Type is
that information to the Ownership and the InvestAmount cannot be made on the first
layer. Additionally the specification of the element ID is optional. This allows the discloser
to specify more than one top element on the first layer of the ArrangementChart.
This means that several persons / organisations can be recorded on the first layer by
repeating the ChildRTP element. In these cases, the information on the persons /
organisations of the ArrangementChart is only given from the second level of the entire
ArrangementChart. The restriction of the ArrangementChart to the specification of five
levels [DAC6_E_MES_069] remains unaffected, i.e. the omitted level is counted in the check.
The example of an ArrangementChart with more than one top element can be found in the
annexes.
Figure 2: ArrangementChartRoot_Type with more than one top element
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3.7.2. Initial disclosures of a marketable arrangement

In the element InitialDisclosureMA it is indicated whether it is the first (initial)
disclosure of a marketable arrangement. Only the specification of the values "true" or "false"
is allowed.
The value "true" may only be specified for the initial disclosure of a marketable arrangement
and for its correction. The element MarketableArrangement needs to be specified with
the value “true” for marketable arrangements [DAC6_E_MES_049] (see chapter 3.7.3.). The
ArrangementID should only be specified for the correction of an initial disclosure of a
marketable arrangement.
Subsequent disclosures of marketable arrangements must always contain the value "false"
in the InitialDisclosureMA element and must be submitted with the
ArrangementID. This may be the case, for example, if not all relevant taxpayers for a
marketable arrangement can be transmitted in one disclosure. The element
MarketableArrangement needs to be specified with the value “true” in these cases.
Disclosures for non-marketable (bespoke) arrangements must always contain the value
"false" for the element InitialDisclosureMA.
3.7.3. Marketable arrangements4

The element MarketableArrangement specifies if an arrangement is marketable or
bespoke. The element is specified with “true” when a marketable arrangement is
transmitted and with “false“ when a bespoke arrangement is transmitted.
The discloser must identify marketable tax arrangements in the disclosure by means of
several elements:
● The value for the element MarketableArrangement must not change for an
arrangement [DAC6_E_MES_010].
● The hallmark “DAC6A3” must be included in the case of all disclosures of
marketable arrangements [DAC6_E_MES_059].
● For initial disclosures related to marketable arrangements, the
InitialDisclosureMA and the MarketableArrangement elements must
contain the input “true” and no ArrangementID may be specified
[DAC6_E_MES_048].
● The InitialDisclosureMA input may not change when submitting corrections
to initial disclosures related to marketable arrangements [DAC6_E_MES_006].
4A marketable arrangement is one that is suitable for use by an additional relevant taxpayer without a need to be
substantially customised.
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● Initial disclosures related to marketable arrangements must not contain a relevant

taxpayer [DAC6_E_MES_071]. Follow-on disclosures (that are not corrections) must
include a relevant taxpayer in all cases [DAC6_E_MES_068].
3.7.3.2. Coherence check for subsequent disclosures

A coherence check for subsequent disclosures of a marketable arrangements is introduced
to ensure the coherence of the disclosure. The system checks if the following “core fields” of
the initial disclosure and the subsequent disclosure are identical:
● ImplementingDate
● Event that triggered the obligation to disclose (Reason)
● Name of the arrangement (Disclosure_Name)
● MainBenefitTest1
● Hallmarks
Note:
3.7.4. If the hallmark “DAC6D1Other” is chosen the free text element

“DAC6D1OtherInfo” will be taken into account for the coherence check as
well. Compliance with the requirements of this chapter is ensured via the
business rule [DAC6_E_MES_074].Language requirements
Data must be transmitted in German. The following key elements may additionally be
submitted in English:
• Description of the arrangement (Disclosure_Description)
• Indication of the relevant national provision (NationalProvision/Text)
• Investment information (ArrangementChart/OtherInfo)
• Description of the hallmark (DAC6D1OtherInfo)
The overarching language element Language can optionally be used to specify the
language in which the key elements will be made.
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Figure 3: Language element
The general language indicated will apply to these key elements as well if no additional
language is indicated in the language attribute for these elements.
The indication "EN" in the overarching element Language leads to rejection by the
business rules if only German language attributes are indicated, as the information is not
consistent. If both German and English language attributes are provided, no rejection will be
made.
Language consistency is controlled by the business rules [DAC6_E_MES_025],

[DAC6_E_MES_026], ["DAC6_E_MES_027], [DAC6_E_MES_028] and [DAC6_E_MES_070].
3.7.5. Input related to tax identification data

Tax identification data (TIN) includes all tax numbers, both German and foreign. The
German tax identification number may be used alternatively for natural persons.
The following rules apply to information concerning tax identification data:
Only one entry may be made for tax identification data relating to one country
[DAC6_E_MES_030] and [DAC6_E_MES_031]. It is possible to specify a German tax
identification number or tax number as well as other foreign tax numbers for one person.
The fields related to tax identification data are mandatory. The entry of a German tax
number must correspond to the standard national scheme without the use of separators
such as slashes.
Example:
NRW 5FFF0BBBBUUUP
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e.g., 5133081508159
Berlin 11FF0BBBUUUUP
e.g., 1121081508150
F stands here for the Federal Tax Office number, B for the district number/area number
within the Tax Office, U is the differentiator and P is the check digit at the end.
State Standard scheme of the Unified federal scheme

states
Baden-Wuerttemberg FF/BBB/UUUUP 28FF0BBBUUUUP
Bavaria FFF/BBB/UUUUP 9FFF0BBBUUUUP
Berlin FF/BBB/UUUUP 11FF0BBBUUUUP
Brandenburg FFF/BBB/UUUUP 3FFF0BBBUUUUP
Bremen FF/BBB/UUUUP 24FF0BBBUUUUP
Hamburg FF/BBB/UUUUP 22FF0BBBUUUUP
Hesse 0FF/BBB/UUUUP 26FF0BBBUUUUP
Mecklenburg-Western FFF/BBB/UUUUP 4FFF0BBBUUUUP

Pomerania
Lower Saxony FF/BBB/UUUUP 23FF0BBBUUUUP
North Rhine-Westphalia FFF/BBBB/UUUP 5FFF0BBBBUUUP
Rhineland-Palatinate FF/BBB/UUUUP 27FF0BBBUUUUP
Saarland FFF/BBB/UUUUP 1FFF0BBBUUUUP
Saxony FFF/BBB/UUUUP 3FFF0BBBUUUUP
Saxony-Anhalt FFF/BBB/UUUUP 3FFF0BBBUUUUP
Schleswig-Holstein FF/BBB/UUUUP 21FF0BBBUUUUP
Thuringia FFF/BBB/UUUUP 4FFF0BBBUUUUP

Table 15: Schema for German tax numbers
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“No TIN” must be entered if no tax identification data is available.
The requirements are checked by the business rules [DAC6_E_MES_051] and

[DAC6_E_MES_052].
3.7.6. Entries regarding the hallmarks

The hallmark “Other” (DAC6D1Other) may only be used if the corresponding description of
the hallmark (DAC6D1OtherInfo) is also filled in [DAC6_E_MES_032] and
[DAC6_E_MES_033].
The hallmarks
● DAC6A1, DAC6A2a, DAC6A2b, DAC6A3

● DAC6B1, DAC6B2, DAC6B3
● DAC6C1bi, DAC6C1c, DAC6C1d
may only be used if the primary benefit or one of the primary benefits is obtaining a tax
advantage (MainBenefitTest1 = “true”) [DAC6_E_MES_047].
3.7.7. Name of the arrangement

This element has to be specified. The text “No Disclosure Name” should be specified if no
name, by which the arrangement is commonly known, exists.
3.7.8. Implementation date

The implementation date has to be specified for two different elements. First, when giving
information about the arrangement (DisclosureInformation) and second, when giving
information about the relevant taxpayer. Different dates can be given for disclosures of a
marketable arrangements. Bespoke arrangements should usually have the same
implementation date for the relevant taxpayer and the arrangement.
The ImplementingDate can be marked as unknown

(DisclosureInformation/ImplementingDate@unknown = “true”).
3.7.9. Indication of national provision

In the element NationalProvision details of the relevant national provisions of all affected
Member States of the European Union, which directly form the basis of the arrangement
must be provided.
The information is given per Member State and should be as accurate as possible.
Note:
The sum of all occurrences of the NationalProvision should not exceed 4,000
characters (per language)
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Note:
The indication of the legal regulations (§§ 138d ff AO) which form the basis of the obligation
to report is insufficient. The entry of filler terms such as "unknown", "unclear", "N/A" or
similar do not in principle fulfil the reporting obligation with regard to the indication of the
legal provisions and can therefore lead to consequences under penalty law.
3.7.10. Input restriction for certain mandatory fields

For the elements
● City
● FirstName
● LastName
● BirthPlace
● TIN (Tax identification number)
at least one character different than a whitespace needs to be specified. Furthermore it is
not allowed to specify a newline character. The restriction is secured by the regular
expression by validation of the xml schema:
.*\S.*
Note:
The business rules [DAC6_E_MES_034], [DAC6_E_MES_035], [DAC6_E_MES_036],

[DAC6_E_MES_038], [DAC6_E_MES_039], [DAC6_E_MES_040], [DAC6_E_MES_041] and
[DAC6_E_MES_044] are obsolete because of the changes of the xml schema. They have been
deleted from chapter 4.1.
3.7.11. Input restrictions for enumeration types

The xml unique feature has been implemented for the elements:
● ReceivingCountries
● CountryExemption
● ConcernedMS
● Hallmark
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Figure 4: XML structure unique constraint
This ensures that the values of those enumeration types can only be specified once. When a
value is specified more than once the disclosure is rejected by the schema validation.
Example:
Figure 5: example for an invalid specification (enumeration types)
3.7.12. „Unknown„ specification (unknown attribute)

The attribute unknown has been added for the following elements:
● TaxpayerImplementingDate
● ImplementingDate
● Amount
● FirstName
● BirthPlace
● BirthDate
This allows to specify the fields as "unknown". This is shown by specifying the attribute
unknown="true" for the element which is marked as unknown.
Analog to the national legislation there are different possibilities for which groups the
attribute unknown="true" is allowed.
Note:
Seite 39 von 72
Please note that if you have this information, you are obliged to include it in the disclosure.
Marking the information as “unknown” is only allowed if mentioned in the national
legislation (e.g. § 138f section 3 number 10 AO).
When an element is marked as unknown="true" it is not allowed to specify information

for this element. When an element is marked as unknown="true" or the attribute
"unknown" is not given, information to this element must be specified. Compliance with
these requirements is ensured by the business rules [DAC6_E_MES_038],
[DAC6_E_MES_040], [DAC6_E_MES_042], [DAC6_E_MES_043], [DAC6_E_MES_080] and
[DAC6_E_MES_081].
The element Amount has additionally the following logic for the attribute currCode:
● When it is marked as unknown = "true", it is not allowed to specify information

for this element and the attribute currCode must not be present.
● When it is marked as unknown = "false" or the attribute is not given,
information must be specified and the attribute currCode must be given.
Figure 6: Valid example for the unknown attribute in an XML
Compliance with these requirements is ensured by the business rules mentioned in the
table. More information on the business rules can be found in chapter 4.1.
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Possible constellations and the concerned business rules can be found in the following table:
Group Element Unknown allowed
Discloser BirthDate No
(DAC6_E_MES_076) BirthPlace No
FirstName No
Intermediaries BirthDate No
FirstName No
RelevantTaxpayers BirthDate No
FirstName No
AssociatedEnterprises BirthDate Yes
(DAC6_E_MES_079) BirthPlace Yes
FirstName No
AffectedPersons BirthDate Yes
BirthPlace Yes
FirstName Yes
Table 16: unknown attribute
4. Notes and error messages

The obliged entity receives a reply via the processing log documenting processing status for
each data disclosure following DAC6 procedure review. The reply is provided based on the
reporting channel used to submit the respective data disclosure. Processing protocols are
provided in the ELMA as XML files and via BOP as PDF documents. A reply is provided as an
XML file as well in the case of an XML upload in BOP. All errors occurring during the
plausibility check are logged in the processing log. A distinction is made between errors and
messages in this context:
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Errors: An error results in the rejection of a complete disclosure. Errors referred to

in the processing log must be corrected and transmitted to the Federal Central
Tax Office in the form of a new disclosure (with new MessageRefID).
Re-sending a rejected report is not a correction disclosure because corrections
are only permitted in the case of disclosures that have previously been
accepted.
Note:
Rejected correction disclosures are not transmitted to the EU but will be
included in the version history. Rejected disclosures have no influence on
follow-on disclosures and are not taken into account for purposes of the
reviews described below. The only exception is for checking the uniqueness of
the MessageRefID.
Note: A note does not result in the rejection of a disclosure. The disclosure is
treated as accepted in the DAC6 system in such cases. Nevertheless, the
disclosure should be corrected if necessary and re-sent to the Federal Central
Tax Office in a correction disclosure.
Errors may also occur upon re-submission following correction of an error reported by the
Federal Central Tax Office thus requiring an error message.
Messages from the processing log are listed in table form, separated according to disclosure
and data, in Chapter 4.1 and Chapter 4.2. This includes the following:
1) Error and note code following by the error text in German

2) Cause of the error/note
3) Solution to resolve the error/note
The error and message codes have a uniform scheme and conform to the following
structure:
<DAC6>_<ErrorOrMessage>_<DeliveryDataOrResult>_<SequentialNo> with:
Term Abbreviations Meaning
DAC6 DAC6 Stands for the DAC6

procedure and is constant.
ErrorOrMessage E Stands for “error” and

indicates an error code
I Stands for “information” and

indicates a note
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Term Abbreviations Meaning
DeliveryDataOrResult MES Stands for “message” and

refers to the complete
disclosure
RES Stands for “result” and

indicates the processing
result
SequentialNo 123 Three-digit sequential

number
Table 17: Structure of error/message codes
The individual components are separated by an underscore “_”.
Example: DAC6_I_MES_952
The error and note codes listed in the table are referenced by “[...]” in the preceding
chapters. XML elements are referenced by example_element in the preceding chapters.
4.1. Errors in a disclosure

The error codes for a disclosure, including the cause and a solution, as described in greater
detail below.
Error code and text Cause Solution/Note
[DAC6_E_MES_001] The XML file you submitted is Please check your entries for
larger than the maximum errors and contact the relevant
<This message could
allowed file size. Federal Central Tax Office
not be processed by
department as needed.
the system because
the maximum Parameter {0} contains the
allowed file size of maximum permitted file size at
{0} was exceeded.> the time of transmission
(currently 40 MB).
[DAC6_E_MES_002] The XML file you sent does not Please check your entries for
conform to the schema. errors and check the sequence of
<Your data disclosure
the elements.
does not conform to
the DAC6 XML
schema.>
Seite 43 von 72
[DAC6_E_MES_004] A DisclosureID was Please include the

<The DisclosureID indicated without specifying the DisclosureID together with
may only be included associated ArrangementID. the corresponding
together with an ArrangementID in all cases.
ArrangementID.>
[DAC6_E_MES_005] The combination of Please check the

<The specified DisclosureID and DisclosureID and the
DisclosureID does ArrangementID cannot be ArrangementID for input
not belong to the found in the system. errors and correct them.
specified
ArrangementID or
vice versa.>
[DAC6_E_MES_006] The input for “initial disclosure of The input for “initial disclosure of
a marketable arrangement” a marketable arrangement”
<The input for an
InitialDisclosureMA (InitialDisclosureMA) (InitialDisclosureMA) may
may not change does not correspond to the not change during a correction;
during a correction.> information provided in the please check and correct your
original disclosure. inputs.
[DAC6_E_MES_007] In the case of a follow-on Please check your entries based

disclosure of relevant taxpayer on the specifications provided in
<Delivery from
data, either not all mandatory Chapter 3.3.
relevant taxpayer
information was provided or
“DAC61104” with
prohibited information was
RefDisclosureID must
provided. Please refer to Chapter
contain relevant
3.3 regarding mandatory fields
taxpayer-related
and prohibited fields in the case
information and may
of follow-on disclosures.
not contain any
arrangement-related
information.>
Seite 44 von 72
[DAC6_E_MES_008] Not all mandatory information Please check your entries based
was provided in the relevant on the specifications provided in
<Delivery from
taxpayer’s overall disclosure. Chapter 3.1.3.
relevant taxpayer
Please refer to Chapter 3.1.3
“DAC61104” without
regarding mandatory fields and
RefDisclosureID must
fields where input is optional.
contain relevant
taxpayer-related and
arrangement-related
information.>
[DAC6_E_MES_009] The DisclosureID referenced Please indicate the

<RefDisclosureID by means of DisclosureID associated with
must refer to a RefDisclosureID originates the partial disclosure containing
partial disclosure from a follow-on disclosure of arrangement-related information.
with arrangement- relevant taxpayer data which
related information.> does not contain any
arrangement-related
information.
[DAC6_E_MES_010] The value for Please check the given

MarketableArrangement ArrangementID and the value
<The value of
does not correspond with the for MarketableArrangement
MarketableArrangem
value of this element in the and correct your entry.
ent must not change
preceding disclosures for this
for an arrangement.>
ArrangementID.
[DAC6_E_MES_011] A disclosure from intermediary or Inclusion of a

<Delivery from
relevant taxpayer “DAC61105” RefDisclosureID is only
either contains a permitted for follow-on
intermediary or
relevant taxpayer RefDisclosureID or does disclosures. The mandatory
“DAC61105” must not contain all necessary information to be included in a
contain arrangement-related disclosure from an intermediary
arrangement-related information. or relevant taxpayer is described
information and may in Chapter 3.1.1.
not include a
RefDisclosureID.>
Seite 45 von 72
[DAC6_E_MES_012] A DisclosureID and a Inclusion of a

<RefDisclosureID RefDisclosureID are RefDisclosureID is not
may only be included in the correction permitted in a correction
contained in a disclosure, although no disclosure for a complete or
correction to a RefDisclosureID was partial disclosure.
follow-on included in the original
disclosure.> disclosure.
[DAC6_E_MES_013] An ArrangementID and a Your first disclosure (follow-on

<RefDisclosureID DisclosureID were indicated disclosure) included a
must not be but no RefDisclosureID. RefDisclosureID. Correction
removed in However, the disclosure to be without inclusion of this ID is not
correction of the corrected is a follow-on permitted.
follow-on disclosure. A correction is only Please correct your entry.
disclosure.> possible if a
RefDisclosureID is
included.
[DAC6_E_MES_015] All mandatory information Please check your entries based

concerning the relevant taxpayer on the specifications provided in
<Complete disclosure
or regarding cross-border tax- Chapter 3.1.2.
from relevant
planning arrangements was not
taxpayer
included in the relevant
“DAC61106” must
taxpayer’s complete disclosure.
contain relevant
taxpayer and
arrangement-related
information and may
not contain a
RefDisclosureID.>
[DAC6_E_MES_016] The format of the given Please revise the structure of the
<The format of the ArrangementID does not ArrangementID to conform to
given ArrangementID correspond to the prescribed the specifications in the data set
does not correspond structure in the data set description
to the prescribed description.
structure.>
Seite 46 von 72
[DAC6_E_MES_017] The specified ArrangementID Please check the

<The specified cannot be found in the system ArrangementID for input
German although it begins with “DE”. errors and correct them.
ArrangementID is
unknown.>
[DAC6_E_MES_018] The format of the Please revise the structure of the

<The format of the DisclosureID specified does DisclosureID to conform to
given DisclosureID not correspond to the structure the requirements set out in the
does not correspond prescribed in the data set data set description.
to the prescribed description. Only disclosure IDs
structure.> with the country code “DE” are
permitted.
[DAC6_E_MES_019] The format of the Please revise the structure of the

<The format of the RefDisclosureID specified RefDisclosureID to conform
given does not correspond to the to the requirements set out in the
RefDisclosureID does structure prescribed in the data data set description.
not correspond to set description.
the prescribed
structure.>
[DAC6_E_MES_020] The RefDisclosureID was Please indicate the

<The RefDisclosureID included without indicated the RefDisclosureID together
may only be included associated ArrangementID. with the corresponding
together with an ArrangementID in all cases.
ArrangementID.>
[DAC6_E_MES_021] The combination of Please check the

<The specified ArrangementID and RefDisclosureID and
RefDisclosureID does RefDisclosureID is not ArrangementID for input
not belong to the available in the system. errors and correct them.
specified
ArrangementID or
vice versa.>
Seite 47 von 72
[DAC6_E_MES_022] The format of the Please revise the format of the

<The specified MessageRefID does not MessageRefID to conform to
MessageRefID does correspond to conform to the the specifications in the data set
not correspond to requirements of the data set description.
description and/or is longer than
the prescribed The MessageRefID may not
structure.> 40 characters.
exceed 40 characters.
[DAC6_E_MES_023] The specified MessageRefID Please check and correct your

was used previously for a input concerning the
<MessageRefID must
be unique> disclosure and is already included MessageRefID.
in the system.
Note:
For each disclosure (including
corrections), a separate, unique
MessageRefID must be
assigned by the discloser.
Please note the specifications for
the structure of the
MessageRefID in the data set
description.
[DAC6_E_MES_024] The time stamp (Timestamp) in Please check and correct the time
<The time stamp in the header is greater than the stamp (Timestamp).
the header must not current system time and is
be in the future.> therefore in the future.
[DAC6_E_MES_025] The description of the Please enter the description of the

arrangement arrangement
<Disclosure_Descripti
on must be in (Disclosure_Description (Disclosure_Description)
German at the least ) was either not included in once with “DE” and once with
and may not be German, or was included twice in “EN” if you want to deliver in both
included twice in the the same language. languages or remove a repetition.
same language.> However, the repeatability of the
element only serves the purpose
of transmission in different
languages.
Seite 48 von 72
[DAC6_E_MES_026] The NationalProvision Please enter the description of the

<NationalProvision was either not in German or was NationalProvision once
must be in German included twice in the same with “DE” and once with “EN” if
at the least and may language. you want to deliver in both
not be included twice However, the repeatability of the languages or remove a repetition.
in the same element only serves the purpose
language.> of transmission in different
languages.
[DAC6_E_MES_027] The description of the hallmark Please enter the description of the
<DAC6D1OtherInfo (DAC6D1OtherInfo) was hallmark (DAC6D1OtherInfo)
must be in German either not included in German, or once with “DE” and once with
at the least and may was included twice in the same “EN” if you want to deliver in both
not be included twice language. languages or remove a repetition.
in the same However, the repeatability of the
language.> element only serves the purpose
languages.
[DAC6_E_MES_028] The investment information Please enter the investment

<OtherInfo must be (OtherInfo) was either not information (OtherInfo) once
in German at the provided in German or was with “DE” and once with “EN” if
least and may not be provided twice in the same you want to deliver in both
included twice in the language. languages or remove a repetition.
same language.> However, the repeatability of the
element only serves the purpose
languages.
Seite 49 von 72
[DAC6_E_MES_029] In the Please check your disclosure

ArrangementChartRoot_T under consideration of the notes
<The first layer of the
ype the element OtherInfo and requirements in chapter
ArrangementChart
has been specified but no 3.7.1. and correct your entry.
can only contain the
information concerning a person
element OtherInfo,
or organisation has been given.
when a person or
organisation has
been specified.>
[DAC6_E_MES_030] More than one TIN for a natural Please enter only one valid TIN
person has the attribute per country.
< The element TIN in
type {0} for TINs {1} “issuedBy” with the same ISO Parameter {0} may have the
may only be country code. following content:
specified once per
 Discloser
country.>
 RelevantTaxpayer
 AssociatedEnterpri
se
 Intermediary
 AffectedPerson
 ArrangementChart
Parameter {1} contains the tax
identification information (TIN)
for the natural person for whom
more than one TIN per country
was input.
Seite 50 von 72
[DAC6_E_MES_031] More than one TIN for an Please enter only one valid TIN
< The element TIN in organisation has the attribute per country.
type {0} for TINs {1} “issuedBy” with the same ISO
Parameter {0} may have the
may only be country code.
following content:
specified once per
 Discloser
country.>
se
 Intermediary
 AffectedPerson
for the organisation for which
more than one TIN per country
was input.
[DAC6_E_MES_032] The description of the hallmark Please include the description of

(DAC6D1OtherInfo) was the hallmark
<The element
DAC6D1OtherInfo specified although the hallmark (DAC6D1OtherInfo) only in
may only be included “Other” (DAC6D1Other) was not cases where the hallmark “Other”
together with the selected. (DAC6D1Other) has been
hallmark selected.
“DAC6D1Other”.>
[DAC6_E_MES_033] The hallmark “Other” Please add a description for the

(DAC6D1Other) was selected, hallmark (DAC6D1OtherInfo).
<The hallmark
however the description of the
“DAC6D1Other” may
only be included hallmark (DAC6D1OtherInfo)
together with the was not included.
element
“DAC6D1Otherinfo”.
>
Seite 51 von 72
[DAC6_E_MES_034] The name of the organisation Please make an entry for the
(OrganisationName) does name of the organisation
<The element
OrganisationName not contain at least one (OrganisationName) that
for organisations in character that is not a conforms to the specifications in
type {0} for TIN {1} whitespace (according to Java the data set description.
must be specified.> definition).
following content:
 Discloser
se
 Intermediary
 AffectedPerson
of the organisation for which no
organisation name
(OrganisationName) was
indicated.
[DAC6_E_MES_035] For natural persons, the tax Please make an entry for the tax
<The element TIN for identification information (TIN) identification number (TIN) for
natural persons in does not contain at least one natural persons that conforms to
type {0} must be character that is not a the specifications in the data set
specified.> whitespace (according to Java description.
definition).
following content:
 Discloser
se
 Intermediary
 AffectedPerson
Seite 52 von 72
[DAC6_E_MES_037] You have included a prohibited Please check your input and
character listed in Chapter 1.2.2 remove the prohibited characters
<The disclosure
in your disclosure. from your disclosure.
includes at least one
prohibited character
combination.>
[DAC6_E_MES_038] A FirstName is marked as Please give the information for

<The element unknown (unknown=“true“) the element FirstName as
FirstName in type {0} and content is specified or is specified in the data set
for TIN {1} must be marked as known description.
specified or marked (unknown=“false” or not Please consider the requirements
as unknown.> specified) and no content is given in chapter 3.7.12.
given.
The parameter {0} may have the
following content:
 Disclosing
 AssociatedEnterprise
 Intermediary
 AffectedPerson
for the natural person, for whom
the FirstName was specified
incorrectly.
Seite 53 von 72
[DAC6_E_MES_040] A BirthPlace is marked as Please give the information for

<The element unknown (unknown=“true“) the element BirthPlace as
BirthPlace in type {0} and content is specified or is specified in the data set
given.
following content:
 Disclosing
 Intermediary
 AffectedPerson
the BirthPlace was specified
incorrectly.
Seite 54 von 72
[DAC6_E_MES_042] A BirthDate is marked as Please give the information for

<The element unknown (unknown=“true“) the element BirthDate as
BirthDate in type {0} and content is specified or is specified in the data set
given.
following content:
 Disclosing
 Intermediary
 AffectedPerson
the BirthDate was specified
incorrectly.
Seite 55 von 72
[DAC6_E_MES_043] A Please give the information for

TaxpayerImplementingDa the element
<The element
te is marked as unknown TaxpayerImplementingDat
TaxpayerImplementi
(unknown=“true“) and e as specified in the data set
ngDate for TIN {0}
content is specified or is marked description.
must be specified or
as known (unknown=“false” Please consider the requirements
marked as
or not specified) and no content given in chapter 3.7.12.
unknown.>
is given.
following content:
 Disclosing
 Intermediary
 AffectedPerson
the
TaxpayerImplementingDat
e was specified incorrectly.
[DAC6_E_MES_045] The time indicated in the time Please check and correct the time
stamp in the header is before 1 stamp (Timestamp).
<The Timestamp in
January 2020 and is therefore
the header must not
outdated.
be before
01/01/2020.>
Seite 56 von 72
[DAC6_E_MES_046] The date of birth (BirthDate) Please check and correct the birth
<The BirthDate is a future date. date (BirthDate).
element in type {0} Parameter {0} may have the
for TIN {1} may not following content:
be a future date.
 Discloser
se
 Intermediary
 AffectedPerson
for the natural person for whom a
birth date (BirthDate) in the
future was indicated.
Seite 57 von 72
[DAC6_E_MES_047] The list of hallmarks The hallmarks A*, B*, Cbi, Cc or Cd

(ListHallmarks) contains may only be used if the main
<The following
one of the hallmarks included in reason for the tax arrangement is
hallmarks may only
{0} although the notation was obtaining a tax advantage
be used if the main
benefit, or one of the made that a tax advantage was (MainBenefitTest1 = “true”).
main benefits, of the not the primary reason for Please check and correct your
arrangement is implementing the tax input.
obtaining a tax arrangement
{0} may have the following
advantage: {0}> (MainBenefitTest1 = content:
“false”).
 DAC6A1
 DAC6A2a
 DAC6A2b
 DAC6A3
 DAC6B1
 DAC6B2
 DAC6B3
 DAC6C1bi
 DAC6C1c
 DAC6C1d
Seite 58 von 72
[DAC6_E_MES_048] The entry indicated that the You have marked your disclosure
initial disclosure concerned a as an initial disclosure of a
<The element
marketable arrangement marketable arrangement.
InitialDisclosureMA
may only be (InitialDisclosureMA = Except where a correction is being
specified as “true” in “true”) and made to the initial disclosure, this
the case of the initial  it was specified that the is only permitted if no
disclosure of a arrangement is not ArrangementID and the
marketable marketable element
arrangement.> (MarketableArrange MarketableArrangement =
ment = “false”) or “true“ have been specified.
 an ArrangementID
was indicated but no
DisclosureID or
 not all previous versions
of this Disclosure
were specified as an
initial disclosure
concerning a marketable
arrangement
(InitialDisclosure
MA = “true”), i.e. it is a
correction of an initial
disclosure concerning a
marketable arrangement.
[DAC6_E_MES_049] No ArrangementID has been Please check your entry under

specified and the disclosure has consideration of the notes and
<Disclosures without
been marked as marketable requirements of chapters 3.7.2.
ArrangementID
(MarketableArrangement= and 3.7.3. and correct your entry.
concerning
marketable “true“). It has therefore not
arrangements need been specified that it is an initial
to contain disclosure of a marketable
InitialDisclosureMA = arrangement
"true".> (InitialDisclosureMA=“f
alse“).
Seite 59 von 72
[DAC6_E_MES_050] The persons/companies included Please enter the persons included

<The in the ArrangementChart in the ArrangementChart
“ArrangementChart” are not identical with those listed exactly as they are listed under
as
of a non-follow-on  RelevantTaxpayerDi
RelevantTaxpayerDisclo
disclosure may only scloser
ser, RelevantTaxpayers,
contain
AssociatedEnterprises or  RelevantTaxpayers
RelevantTaxpayerDis
closer, AffectedPersons.  AssociatedEnterpri
RelevantTaxpayers, ses
AssociatedEnterprise
 AffectedPersons.
s or AffectedPersons
that have already
been specified.>
[DAC6_E_MES_051] The indication of a German tax The tax identification number (DE-
identification number (DE-TIN) TIN) indicated issued by Germany
<The element TIN in
for natural persons was not input for natural persons does not
type {0} for TIN {1}
as conform to these requirements.
does not conform to
Please correct your entry.
the specifications.>  “No TIN”,
 11 digits (Tax ID, numeric
following content:
only), or
 Discloser
 13 digits (tax number,
numeric only).  RelevantTaxpayer
se
 Intermediary
 AffectedPerson
Parameter {1} includes the tax
identification number (DE-TIN)
issued by Germany for a natural
person that does not conform to
these requirements.
Seite 60 von 72
[DAC6_E_MES_052] The indication of a German tax The TIN indicated for the
identification number (DE-TIN) organisation concerned issued by
<The element TIN in
for organisations was not input Germany does not conform to
type {0} for TIN {1}
as conform to the requirements.
does not conform to
Please correct your entry.
the specifications.>  “No TIN” or
 13 digits (tax number,
following content:
numeric only).
 Discloser
se
 Intermediary
 AffectedPerson
Parameter {1} includes the tax
identification number (DE-TIN)
issued by Germany for the
organisation that does not
conform to these requirements.
[DAC6_E_MES_053] The NationalProvision has Please check and correct your

been indicated more than once input concerning applicable
<NationalProvision
may only be for the same state (several NationalProvision.
indicated once per instances of
NationalProvision
state.>
reference the ISO country code).
Seite 61 von 72
[DAC6_E_MES_054] The persons/companies included Please enter the persons included

<The in the ArrangementChart in the ArrangementChart
ArrangementChart of are not identical with those listed exactly as they are listed under
a follow-on as RelevantTaxpayers, RelevantTaxpayers,
AssociatedEnterprises or AssociatedEnterprises
disclosure may only
AffectedPersons. and AffectedPersons.
contain
RelevantTaxpayerDis
closer,
RelevantTaxpayers,
AssociatedEnterprise
s or AffectedPersons
that have already
been specified.>
[DAC6_E_MES_055] The country code “DE” was used, You have not entered a five-digit
but the postal code (Postcode) postcode for a German address.
<The element
Postcode in type {0} does not include five digits. Please check and correct your
for TIN {1} does not input.
conform to the
specifications.>
following content:
 Discloser
se
 Intermediary
 AffectedPerson
identification information (TINs)
of the organisation or natural
person for whom a German postal
code (Postcode) that did not
conform to conform to the
requirements was indicated.
Seite 62 von 72
[DAC6_E_MES_056] The characters for the element Please check your entry and
NationalProvision for one of the correct your information under
<The number of
languages German or English consideration of the requirements
characters for all
exceed the allowed maximum of in chapter 3.7.9.
occurrences of
4.000 characters.
NationalProvision
per language must
not exceed 4.000
characters.>
[DAC6_E_MES_058] The specified time stamp Please check and correct the
(Timestamp) is later than the specified time stamp
<The time stamp of a
correction must be time stamp (Timestamp) for (Timestamp).
earlier than that of the disclosure to be corrected.
the disclosure to be
corrected.>
[DAC6_E_MES_059] A marketable arrangement Please check and correct your

(MarketableArrangement entry concerning hallmark
<Complete or partial
disclosures of =”true”) was transmitted for (Hallmark) “DAC6A3”.
German marketable this ArrangementID and
arrangements must information concerning the
contain the hallmark hallmarks were specified. The
“DAC6A3”. > entry related to hallmark
(Hallmark) “DAC6A3” does not
correspond to the preceding
entry concerning the respective
arrangement.
[DAC6_E_MES_067] For OtherInfo in the Please make an entry for

<The element arrangement chart contains not OtherInfo that conforms to the
OtherInfo in the at least one character that is not specifications in the data set
arrangement chart a whitespace (according to Java description.
must contain at least definition).
one character that is
not a whitespace
(according to Java
definition).>
Seite 63 von 72
[DAC6_E_MES_068] The information was provided At least one

<Subsequent
that a subsequent disclosure RelevantTaxpayer must be
concerning a marketable specified when sending a follow-
disclosure
arrangement is involved on disclosure concerning a
concerning
marketable (InitialDisclosureMA = marketable arrangement.
arrangements must “false” and
Please supplement information
contain at least one MarketableArrangement = concerning the
“true”). Nevertheless no
relevant taxpayer. > RelevantTaxpayer.
information about a
RelevantTaxpayer is
included.
[DAC6_E_MES_069] The ArrangementChart Please check your input

including root object concerning
<The
ArrangementChart (StartingPoint) contains more ArrangementChart and
may contain a than five levels. conform it to the specifications
maximum of five contained in Chapter 3.7.1.
levels.>
[DAC6_E_MES_070] The name of the organisation Please check and correct your
(OrganisationName) was input of the name of the
<OrganisationName
entered twice with the same organisation
may not be included
twice in the same language. (OrganisationName).
language.>
[DAC6_E_MES_071] The entry indicated that the The transmission of the initial
initial disclosure concerned a disclosure concerning a
<The initial
marketable arrangement marketable arrangement is only
disclosure
(InitialDisclosureMA = permissible without relevant
concerning a
“true”) and relevant taxpayer- taxpayer-related information.
marketable
related information (e.g., Please check and correct your
arrangement must
concerning associated input.
not contain any
relevant taxpayer- enterprises) was included.
related information.>
Seite 64 von 72
[DAC6_E_MES_072] A person/enterprise was A person/organisation may only

referenced twice in the appear once in the
<The persons or
organisations ArrangementChart. ArrangementChart. Please
included in the check and correct your input.
ArrangementChart
may only appear
once.>
[DAC6_E_MES_074] A subsequent disclosure of a The parameter {0} may have the

marketable arrangement was following content:
<The content of the
submitted
following core  - ImplementingDate
elements {0} is not (MarketableArrangement
= true and  - Reason
identical to the
InitialDisclosureMA =
content of the core  - Disclosure_Name
false; no
elements from the
RefDisclosureID is  - MainBenefitTest1
initial disclosure.>
contained in the XML file).
 - Hallmarks
The information indicated in the
If there are several fields with
core elements is not identical to
errors, the information is listed
the information in the core
comma-separated.
elements of the initial disclosure
of this arrangement. Please check your given
information in the core elements
and correct them to be identical
to the information in the initial
disclosure of the arrangement.
Please observe the specifications
from chapter 3.7.3.2.
Seite 65 von 72
[DAC6_E_MES_075] A correction of an initial The parameter {0} may have the

disclosure of a marketable following content:
<The content of the
arrangement hast been
following elements  - Language
transmitted (DisclosureID is
{0} are not identical
contained in the XML file;  - Disclosure_Name
to the content of the
InitialDisclosureMA=true).
elements in the  - NationalProvision
previous version of However, the contents of the
 - MainBenefitTest1
the initial elements mentioned are not
disclosure.> identical to the previous version  - Hallmarks
of this disclosure.
If there are several fields with
errors, the information is listed
comma-separated.
Please check your given
information in the elements
mentioned and correct them to be
identical to the information in the
initial disclosure of the
arrangement.
Please observe the specifications
from chapter 3.4.4.
[DAC6_E_MES_076] At least one of the elements The information concerning the

<Information FirstName, BirthPlace or disclosing person/organisation
concerning the BirthDate has been marked must not be marked as unknown.
Please correct your entry
discloser must not be as unknown
concerning the attribute
marked as unknown> (unknown=“true“) in the type
Disclosing. unknown.

<Information FirstName, BirthPlace or intermediary must not be marked
concerning the BirthDate has been marked as unknown. Please correct your
as unknown entry concerning the attribute
intermediary must
not be marked as (unknown=“true“) in the type unknown.
unknown.> Intermediary.
Seite 66 von 72

<Information FirstName, BirthPlace or relevant taxpayer must not be
concerning the BirthDate has been marked marked as unknown. Please
as unknown correct your entry concerning the
relevant taxpayer
must not be marked (unknown=“true“) in the type attribute unknown.
as unknown.> RelevantTaxpayer.
[DAC6_E_MES_079] The elements FirstName has The element FirstName of an

<Information been marked as unknown associated enterprise must not be
concerning the (unknown=“true“) in the type marked as unknown. Please
associated AssociatedEnterprise. correct your entry concerning the
enterprises must not attribute unknown.
be marked as
unknown.>
[DAC6_E_MES_080] The ImplementingDate is Please give the information for

marked as unknown the element
<The element
ImplementingDate (unknown=“true“) and ImplementingDate as
has to be specified or content is specified or is marked specified in the data set
marked as as known (unknown=“false” description.
unknown.> or not specified) and no content Please consider the requirements
is given. given in chapter 3.7.12.
[DAC6_E_MES_081] The element Amount is marked Please give the information for
<The element as unknown the element Amount as specified
Amount must be (unknown=“true“) and in the data set description.
specified including content or the attribute Please consider the requirements
the currCode or currCode is specified. Or it is given in chapter 3.7.12.
marked as marked as known
unknown.> (unknown=“false” or not
specified) and no content is given
in the element or the attribute
currCode.
Seite 67 von 72
[DAC6_E_MES_083] The disclosure contains the value Please remove the value “GB”
<The element „GB” in the element from the element
ConcernedMSs ConcernedMSs. This value is ConcernedMSs.
contains the value not allowed since the Brexit took
Note:
"GB" for Great place on 01.01.2021.
The obligation to disclose remains
Britain.>
if at least one member state of
the EU and another state is
concerned, see also section 138d
paragraph 2 sentence 1 number 2
German fiscal code.
[DAC6_E_MES_084] A follow on disclosure has been The referenced disclosure of the

transmitted but the disclosure intermediary needs to be
<The element
which was reference by the corrected that the element
ConcernedMSs of the
referenced disclosure RefDisclosureID contains ConcernedMSs does not
contains the value the value “GB” in the element contain the value „GB“. Please
"GB" for Great ConcernedMSs. contact the Creator of the
Britain.> referenced disclosure.
Note:
The follow-on disclosure can only
be sent after the referenced
disclosure has been successfully
corrected.
[DAC6_E_MES_085] The disclosure contains at least Only country codes of EU-member

one country code of a non EU- states may be indicated in the
<The element
member state in the element element CountryExemption.
CountryExemption of
CountryExemption.
an intermediary Please correct your indications for
contains at least one the element CountryExemption to
country code of a conform to the specifications in
non EU-member the data set description.
state.>
Table 18: General errors
4.2. Delivery-related notes

Notes indicate inconsistent information, among other things, but are only a
recommendation for action since the disclosure will not be rejected absent an error note.
Seite 68 von 72
Note code Cause Note
[DAC6_I_MES_003] The ISO country codes contained Not all EU member states listed
the elements: in the disclosure (e.g., for the
<Not all the states
address) were specified under
listed have been  ReceivingCountry
specified under the the ConcernedMSs element.
 Address/Country
ConcernedMSs Please check your information
element.>  ResCountryCode related to the member states
concerned for completeness.
 TIN/issuedBy
 CountryExemption
 NationalProvision/
Country
are not indicated for all relevant
member states
(ConcernedMSs).
[DAC6_I_MES_004] The implementing date The reporting obligation only

(ImplementingDate) is before applies from 25 June 2018.
<The input in the
25 June 2018. Please check your information
ImplementingDate
related to the implementing
element should not
be prior to date (ImplementingDate)
25/06/2018.> for correctness.
[DAC6_I_MES_005] The birth date (BirthDate) Please check your entry related
<The BirthDate indicated is prior to 1 January to the birth date (BirthDate)
element in type {0} 1900. for correctness.
for TIN {1} should not Parameter {0} may have the
be before following content:
01/01/1900.>
 Discloser
 AssociatedEnterp
rise
 Intermediary
 AffectedPerson
for the natural person for whom
Seite 69 von 72
Note code Cause Note

a birth date (BirthDate) prior
to 1 January 1900 was specified.
[DAC6_I_MES_006] The disclosure was accepted {0} contains the assigned

without errors. ArrangementID
<The following new
Arrangement ID has
been assigned: {0}>
[DAC6_I_MES_007] The disclosure was accepted {0} contains the assigned

without errors. DisclosureID
<The following new
Disclosure ID has
been assigned: {0}.>
[DAC6_I_RES_001] The disclosure was successfully {0} may include the following
transferred to the administrative contents:
<The disclosure was
procedure.
successfully received  “Productive
in the {0} environment”
environment.>
 “Test environment”
[DAC6_I_RES_002] Data included in the disclosure  {0} may include the following
were successfully verified. contents:
< The disclosure was
verified with the accepted
following result:
rejected
 Delivery was
 {1} contains error codes
{0}.
(see Chapter4.1)
 {1} Errors
 {2} contains note codes
were logged
(see Chapter 4.2)
(E_MES)
 {2} Notes, i.e.
Data were
inconclusive,
but not
rejected
(I_MES)>
Table 19: Messages
Seite 70 von 72
5. Annexes
5.1. Glossary
The glossary is available on the website of the department automatic exchange of tax
arrangements [Link].
5.2. Data set description

The data set description is available on the website of the department automatic exchange of
tax arrangements [Link].
5.3. Example xml files

Additional example xml files are available on the website of the department automatic
exchange of tax arrangement [Link].
Seite 71 von 72
Imprint
Publisher:
Federal Central Tax Office
An der Küppe 1
53225 Bonn
Phone: +49 228 406-0
Web: www.bzst.bund.de
Contact person:
Division St I A 2, Automatic Exchange of Tax Arrangements (DAC6) Department
Contact details:
Phone: +49 228 406 2333
Fax: +49 228 406 3119
E-Mail: [email protected]
De-Mail: [email protected]
Last updated:
Version 2.0, 01/06/2021
Photo credits:
Cover: Hardy Welsch (http://www.hardy-welsch.de)
Text:
Federal Central Tax Office
www.bzst.bund.de

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Communication Manual

Automatic exchange of tax

3.3. Follow-on disclosure ..........................................................................................................................25

0. Information about this document

Document title Procedure description, responses and business rules

Last revised on 01/06/2021

Link Website Federal Central Tax Office

0.1. Change history

Document XML Date Change

0.1 2.06 (EU) 07/10/2019 Initial creation

0.3 3.02 (EU) 20/04/2020 Deletion of Business Rule [DAC6_E_MES_054] and

Document XML Date Change

1.1 3.02 (EU) 29/06/2020  Relocation and concretization of the note

1.2 3.02 (EU) 31/07/2020  Concretisation concerning ELSTER certificates

Document XML Date Change

1.3 3.02 (EU) 08/09/2020  Clarification of mandatory fields in chapter

1.4 3.02 (EU) 28/09/2020  Deletion of business rule [DAC6_E_MES_049]

1.5 3.02 (EU) 12/11/2020  Correction of the text concerning business

1.6 3.02 (EU) 04/12/2020  Change of business rule [DAC6_E_MES_068]

Document XML Date Change

1.7 3.02 (EU) 01/04/2021  Addition of chapter 3.1.4. Subsequent

1.8 3.02 (EU) 01/06/2021  Clarification in chapter 3.1. Complete

2.0 4.01 (EU) 01/06/2021 Adaptation of the communication manual due to

Document XML Date Change

0.2. Purpose of this document

Chapter 5 lists all the annexes related to this document.

1.2. General information

1.2.1. File size limit

1.2.2. Character set and encoding

Characters Description UTF 8 Code

-- Minus sign Minus sign U+002DU+002D

/* Fraction stroke Asterisk U+002FU+002A

&# Ampersand and pound sign U+0026U+0023

2. Process description and IDs

2.1. Legal bases

The Directive obliges EU Member States to automatically exchange cross-border

Arrangement-related information must be reported, including information on how the tax

2.2. Simplified description of the procedure

2.3. Electronic data transmission

‒ XML web upload via BOP

‒ Electronic mass data interface (ELMA)

1 Federal Gazette 2019 Part I No 52 of 30/12/2019

2.3.1. Individual data transmission via BOP

2.3.2. XML web upload via BOP

In addition, registration with the relevant department “Automatic exchange of tax-planning

2.3.3. Transmission via the ELMA interface

2.3.4. Distinction to the XML upload via BOP

2.4. Description and meaning of identification numbers

3.1. Complete disclosure

3.1.1. Complete disclosure by an intermediary/relevant taxpayer with a non-EU

Mandatory fields for a complete disclosure by an intermediary/relevant taxpayer with a

Mandatory fields for a complete disclosure by an intermediary/relevant taxpayer with a

Identification data concerning the disclosing entity (Disclosing/ID)

Intermediary’s nexus to Germany

Initial disclosure of a marketable arrangement (InitialDisclosureMA)

Transmission of a marketable arrangement (MarketableArrangement)

(At least one) Relevant taxpayer (RelevantTaxpayers/RelevantTaxpayer)

Implementation date (DisclosureInformation/ImplementingDate or

Name of the arrangement (DisclosureInformation/Summary/Disclosure_Name)