Luxembourg Implements the Mandatory Disclosure Regime (DAC 6): Moving towards DAC 6 Readiness
After the training the participant shall be able to:
- have an overview of DAC6, an EU Directive which requires tax intermediaries 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
- 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
Who is the course aimed at?
Professionals of the financial sector and tax managers of multinational groups that would like to gain a clear view on the impact of the new reporting obligations on their investments structured via Luxembourg and the potential obligations of taxpayers. This training may further be of interest for tax intermediaries that may have reporting obligations under DAC 6.
At the end of the training, the participants will receive a certificate of attendance delivered by the House of Training.
The lecturer is an International Tax Partner with a large tax advisory firm in Luxembourg where he is also heading the Transfer Pricing practice. A tax professional since 2003, he has experience in Luxembourg and international taxation with a focus on alternative Investments (private equity, real estate, sovereign wealth funds, hedge funds), mergers & acquisitions and multinational groups. He advises clients on all direct tax aspects regarding deal structuring, maintenance, reorganisations and exit planning.