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
- 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.
The lecturer is a Principal in the International and Corporate Tax department with a large tax advisory firm in Luxembourg.
A tax professional since 2011, the lecturer worked in the accounting sector for 2 years in France before focusing on international tax in Luxembourg. The lecturer has experience in relation to the structuring of Alternative Investments via Luxembourg (private equity, real estate, hedge funds, debt funds, etc.) as well as mergers & acquisitions (multinational groups). The lecturer advises clients on all direct tax aspects regarding deal structuring, maintenance, reorganisations and exit planning. The lecturer is a member of the Core Transfer Pricing Team of an independent advisory firm.
Support de cours
Pour des raisons de respect de l'environnement veuillez noter qu'aucun support papier ne vous sera fourni lors de votre formation. Votre support de cours peut être téléchargé gratuitement avant le début du cours via notre portail client (télécharger ici le guide du portail client). Vous pourrez ainsi le consulter sur l’écran de votre appareil mobile ou l'imprimer en cas de besoin. Si votre inscription a été effectuée par un responsable formation de votre entreprise veuillez le contacter pour qu'il puisse vous y donner accès ou vous l'envoyer.
At the end of the training, the participants will receive a certificate of attendance delivered by the House of Training.