Intermediaries that do not comply correctly or late with the reporting obligations under DAC6 can be sanctioned with administrative fines. These fines are regulated by Royal Decree of May 20, 2020. This Royal Decree is now nullified by the Council of State in its judgment of May 10, 2023, due to the irresponsible distinction made in the Royal Decree between different categories of intermediaries with a reporting obligation. As a result of this judgment, it should now also be possible to impose fines lower than the legally stipulated minima in extenuating circumstances. Once again, the government has no objection to the conversion of DAC6.
Source Tiberghien
