Executive summary

The Portuguese Tax Authority (the PTA), on 20 January 2021, issued guidance (the Guidance) on the application of Law nr. 26/2020 (the Law), of 21 July 2020, as further amended by Decree-Law nr. 53/2020, of 11 August 2020, which implemented the European Union (EU) Directive 2018/822 on the mandatory disclosure and exchange of cross-border arrangements (DAC 6 or the Directive). The …