Executive summary
In October 2019, the French Tax Code (FTC) was supplemented with Articles 1649 AD to 1649 AH, implementing the European Union (EU) Directive 2018/822 of 25 May 2018 on the mandatory disclosure and automatic exchange of cross-border tax arrangements (referred to as DAC6 or the Directive).
On 9 March 2020, the French Tax Authorities (FTA) published official detailed draft guidance (referred to herein as the official tax guidelines or draft guidance) regarding the interpre…