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
Information to be reported
Competing reporting obligations
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
Professionals of the financial sector and tax managers of multinational groups that would like to gain a clear view on the impact
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 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.
At the end of the training, the participants will receive a certificate of attendance delivered by the House of Training.
The course material can be downloaded free of charge via your portal the day before the start of the course (download the Client Portal User’s Guide here).