On June 25th 2018, DAC 6 entered into force. This means that, once the directive transposed in Luxembourg by 2020, any arrangement made after June 25th 2018 and meeting DAC 6's criteria will have to be reported!
This Directive is the fifth amendment of the Directive on Administrative Cooperation (2011/16/EU) and introduces the mandatory exchange of information relating to potentially aggressive cross-border tax-planning arrangements. The reporting will have to be done by the intermediaries, meaning anyone involved in the arragement. Involvement may be the design, the selling, the organisation or management of the implementation, etc.
The first reporting will start on August 31st, 2020 and will concern arrangements made since the date of entry into force (June 25, 2018). The monitoring phase has therefore already started…
Source: Sia Partners
Publié le 27 août 2018