DAC 6 Readiness - Luxembourg Implementation of the EU Mandatory Disclosure Regime and Recent Updates

After the training the participant shall be able to:

• have an overview of DAC6, an EU Directive which requires tax intermediaries or taxpayers to report cross-border arrangements that contain at least one of the hallmarks (characteristics or features of a cross-border arrangement) defined in the Directive
• understand the new reporting obligations that apply for arrangements implemented as from 25 June 2018
• understand when the reporting obligations are shifted to the taxpayer because of a professional privilege
• have a view on timing aspects and potential penalties
• understand the mechanics of the hallmarks and the main benefit test (that needs to be fulfilled for many hallmarks to result in reporting obligations)
• have a clear view on how to deal with these obligations in practice and their impacts on internal procedures
• understand the various recent updates brought by the Luxembourg tax authorities.

• Introduction
• Design principles and main objectives of mandatory disclosure regimes
• Overview of the new disclosure regime
• Definition of tax intermediaries
• Reportable arrangements
• Information to be reported
• Reporting responsibilities
• Competing reporting obligations
• Timing aspects
• Penalties for non-compliance
• Analysis of the hallmarks that may trigger reporting obligations
• Understanding of the main benefit test and its importance in the new reporting regime
• Determining reportable cross-border arrangements
• Case studies

At the end of the training, the participants will receive a certificate of attendance delivered by the House of Training.