Luxembourg Implements the Mandatory Disclosure Regime (DAC 6): What does it mean for investors, multinationals and tax intermediaries?

Contents:

On 26 July 2019, the Luxembourg parliament adopted the draft law for implementing DAC 6 into Luxembourg internal law. DAC 6 requires tax intermediaries to report certain cross-border arrangements that contain at least one of the hallmarks (that are characteristics or features of cross-border arrangements) defined in the Directive. 

It is common knowledge that the investment and business activities of Luxembourg companies often have a cross-border dimension. In all these cases, the question needs to be answered as to whether or not a particular piece of advice is reportable. Therefore, the potential reporting obligations under the mandatory disclosure regime will become an integral part of each and every tax analysis, impacting not only tax advisers but also lawyers, accountants and, ultimately, the investors themselves. In this regard, the vague definitions and concepts used in DAC 6 for the determination of reportable cross-border arrangements can be unclear at times 

This conference aims at providing participants with a clear overview of the new mandatory disclosure regime and how to determine reportable arrangements in practice. Several presentations will be followed by a panel discussion during which professionals from different areas will share their views on and experience with DAC 6. The focus of the conference will be on Alternative Investments (Private Equity, Real Estate, Infrastructure, etc.) and multinational groups in Luxembourg.

Program

1:30 PM – 2:00 PM Registration

2:00 PM – 3:00 PM The New Mandatory Disclosure Regime (DAC 6)

• Purpose and design principles of the mandatory disclosure regime
• Key features of the mandatory disclosure regime  
• Analysing the hallmarks that may trigger reporting obligations
• The importance of the main benefit test (“MBT”) when determining reportable cross-border arrangements
• How to manage reporting obligations in practice
• Practical case studies

Oliver R. Hoor, Tax Partner, ATOZ Tax Advisers

3:00 PM – 3:15 PM The implementation of DAC 6 across Europe – A Snapshot

Fanny Bueb, Tax Director, ATOZ Tax Advisers

3:15 PM – 3:30 PM Managing the implementation of DAC 6 in Europe: A case study of a multinational

Linda Taing, Tax Manager, Global Tax Operations & Strategy, Multinational

3:30 PM – 4:00 PM Coffee break

4:00 PM – 4:45 PM Panel discussion

The implementation of DAC 6: What does it mean for Luxembourg ?

Moderator: 

Nic Müller
Associate Partner, KPMG Audit

Panellist:

Linda Taing
Tax Manager, Global Tax Operations & Strategy, Multinational 

Vilma Domenicucci
Senior Tax Adviser, Association of the Luxembourg Fund Industry (ALFI)

Oliver R. Hoor
Tax Partner, Head of Transfer Pricing and the German Desk, ATOZ Tax Advisers

Adrian Sedlo
Founding Partner, Sedlo Law Firm

4:45 PM – 4:50 PM Closing remarks

Registration fee:  195 € VAT excl. – early bird: 15% off if subscription before September 15.

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