Effective DAC8 compliance requires the right people in the right roles. This article outlines the key roles and skills needed for a DAC8 compliance team.
Core Roles
DAC8 Compliance Manager. The overall owner of DAC8 compliance, responsible for strategy, planning, and stakeholder management. This person needs strong knowledge of EU tax reporting frameworks, project management skills, and the ability to communicate compliance requirements to both technical and business teams.
Tax Reporting Specialist. The subject matter expert on DAC8/CARF reporting requirements, including XML schema interpretation, data field specifications, and national transposition variations. This role requires deep tax technical knowledge and attention to detail.
Data Engineer. Responsible for building and maintaining the data pipelines that feed the DAC8 reporting system. This role requires skills in data integration, ETL processes, database management, and XML generation.
Compliance Operations Analyst. Handles the day-to-day operational aspects of DAC8 compliance, including monitoring data quality, managing the look-back process, processing corrections, and coordinating with the competent tax authority.
Legal and Privacy Advisor. Provides guidance on GDPR compliance, national transposition interpretation, and regulatory risk management. This role may be filled by external counsel for smaller CASPs.
Team Size
Team size depends on the CASP's scale. Small CASPs may cover DAC8 with one to two dedicated personnel supplemented by external advisors. Medium CASPs typically need three to five dedicated team members. Large CASPs may require a team of five or more, plus technology and operations support.
Skills Development
DAC8 is a new requirement, and few individuals have direct experience. CASPs should invest in training programs that cover the DAC8/CARF framework, the XML schema, and the specific transposition requirements of their home jurisdiction. Cross-training with CRS and FATCA teams (where applicable) can accelerate skill development.
Conclusion
DAC8 compliance is a team effort that requires a blend of tax, technical, operational, and legal skills. CASPs that build capable teams early will be better positioned to meet their reporting obligations accurately and efficiently.
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