Dac6

Council Directive (EU) 2018/822 amending Directive 2011/16/EU (“DAC6”) impacts the professionals of the financial sector and their clients.

In a tax environment that is becoming more and more transparent, the DAC6 regulation introduces the mandatory exchange of information for reportable cross-border arrangements within the EU.

This regulation requires intermediaries such as banks, asset managers, life insurance companies and advisors to ensure appropriate processes and procedures are in place 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 DAC6.

Some of the hallmarks should be corroborated with a main benefit test with respect to the tax advantage of the arrangement.

Depending on its DAC6 qualification (promoters, service providers, taxpayers) and the other actors involved in the arrangement structures, the concerned market players may have reporting obligations regarding pre-existing and new arrangements.

By the end of the course, participants will be able to:

• understand the key principles of DAC6;
• explain the purpose and the mechanism of the DAC6 rules and their general impacts;
• identify the role and the related obligations of their organisation on the DAC6 scene;
• define and identify a reportable cross-border arrangement under DAC6;
• detect and escalate potential hallmarks in their daily business;
• list the main elements to be reported and the associated timeline;
• understand how to ensure a suitable compliance framework.

• Context and introduction
• Concerned market players
• Scope of reportable cross-border arrangements
• Hallmarks
• Reporting obligations in Luxembourg

An attendance certificate will be sent to participants.

This training will be coordinated by Murielle Filipucci and Pierre Kirsch, Partners at PwC Luxembourg.

• Murielle Filipucci is a partner in the Tax department at PwC Luxembourg with over 30 years of experience in international taxation. She serves as head of markets and network in the banking sector at PwC Luxembourg and has led the Banking Tax service at PwC Global since July 2021. Murielle manages a team of 60 professionals providing tax advice, compliance, and reporting services for the financial sector and leads the PwC Luxembourg country programme for Italy. She holds Luxembourg taxation qualifications and is active in key industry bodies, including the Luxembourg Banking Association tax committee and the Italo-Luxembourg Chamber of Commerce. Additionally, she represents PwC Luxembourg within the financial services tax network and serves on the supervisory board of PwC Société Coopérative and the board of PwC TIR S.à.r.l., a subsidiary offering tax reporting services such as FATCA, CRS, and withholding tax relief.
• Pierre Kirsch is a partner in the Luxembourg financial services tax practice with over 30 years of experience serving clients in banking, insurance, and asset management. He leads a team specialising in tax compliance analysis for onboarding banking clients and investors into complex alternative fund structures. Pierre and his team advise financial sector actors in Luxembourg and internationally, helping clients review onboarding and tax reporting processes, implement controls, and define organizational roles. He contributed to establishing PwC Regulated Solutions S.à r.l., managing daily operations, and supports PwC’s financial services clients with consulting and reporting on operational taxes including FATCA, CRS, QI, and CbCR.