Luxembourg Implements the Mandatory Disclosure Regime (DAC 6): Moving towards DAC 6 readiness at five to twelve
On 1 July 2020, the mandatory disclosure regime (MDR) entered into force with first reporting deadlines set at the beginning of 2021. With few months left in 2020, intermediaries and taxpayers have to urgently prepare for the new reporting obligations in order to mitigate the risk of penalties. As the MDR applies with retroactive effect, cross-border arrangements implemented since 25 June 2018 have to be reviewed “now”.
The MDR introduces some vague definitions and concepts that can, at times, make it difficult for practitioners to determine as to whether or not a specific cross-border arrangement is reportable. Therefore, it is crucial to develop a clear understanding of the hallmarks and the main benefit test (MBT).
This is the first of two briefings on the MDR that aims at providing participants with clear guidance on how to “move towards DAC 6 readiness”.
- Key features of the disclosure regime
- Arrangements, intermediaries and other interpretation issues
- The hallmarks of reportable arrangements
- The main benefit test – Developing a reasonable approach
- Considering guidance released by Luxembourg and other EU Member States
- Managing DAC 6 obligations in practice
Oliver R. Hoor is a Partner in the International and Corporate Tax department of ATOZ. A tax professional since 2003, Oliver 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. Oliver advises clients on all direct tax aspects regarding deal structuring, maintenance, reorganisations and exit planning. He is Head of Transfer Pricing and the German Desk.
La société Legitech a obtenu l’agrément du Barreau de Luxembourg.
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