Council Directive (EU) 2018/822 amending Directive 2011/16/EU ("DAC 6") is currently the hot topic in tax that will impact very shortly the professionals of the financial sector and their clients.
In a tax environment becoming more and more transparent, the DAC 6 regulation introduces the mandatory exchange of information for reportable cross-border arrangements within the EU.
Indeed, this regulation requires from intermediaries such as banks, asset managers, life insurance companies, advisors to ensure appropriate processes and procedures to identify the potential reportable cross-border arrangements.
In this respect, various hallmarks have been elaborated to assist the intermediaries with the analysis of the potential arrangements falling within the scope of DAC 6. Some of the hallmarks should be corroborated with a main benefit test with respect to the tax advantage of the arrangement.
Depending on its DAC 6 qualification (promoters, service providers, taxpayers) and the other actors involved in the arrangement structures, the concerned market players may have reporting obligations regarding preexisting and new arrangements.
By the end of the course, participants will be able to:
- have an overview of the directive
- understand the reporting obligations
- understand the mechanism of the hallmarks
- Context and introduction
- Concerned market players
- Scope of reportable cross-border arrangements
- Reporting obligations in Luxembourg
Who is the course aimed at?
- Compliance and/or tax functions from banks
- Asset managers and insurance undertakings
An attendance certificate will be sent to participants.
This training will be coordinated by Murielle Filipucci, Partner at PwC Luxembourg and by Pierre Kirsch, Tax partner at PwC Luxembourg and the authorised manager of our PFS Tax Information Reporting, where he is in charge of all services around tax transparency and automatic exchange of information.