Council Directive (EU) 2018/822 amending Directive 2011/16/EU (“DAC6”) impacts the professionals of the financial sector and their clients.
In a tax environment that is becoming more and more transparent, the DAC6 regulation introduces the mandatory exchange of information for reportable cross-border arrangements within the EU.
This regulation requires intermediaries such as banks, asset managers, life insurance companies and advisors to ensure appropriate processes and procedures are in place to identify the potential reportable cross-border arrangements. In this respect, various hallmarks have been elaborated to assist the intermediaries with the analysis of the potential arrangements falling within the scope of DAC6.
Some of the hallmarks should be corroborated with a main benefit test with respect to the tax advantage of the arrangement.
Depending on their DAC6 qualification (promoters, service providers, taxpayers) and the other actors involved in the arrangement structures, the concerned market players may have reporting obligations regarding pre-existing and new arrangements.
This module is part of our Automatic Exchange of Information (AEOI) training curriculum.
Duration: 4h
Language: Available in English, German and French. The supporting material is only available in English.
Number of participants: up to 15
Available under intra-company course (i.e. dedicated session)
Objectives
By the end of the course, participants will be able to:
- understand the key principles of DAC6;
- explain the purpose and the mechanism of the DAC6 rules and their general impacts;
- identify the role and the related obligations of their organisation on the DAC6 scene;
- define and identify a reportable cross-border arrangement under DAC6;
- detect and escalate potential hallmarks in their daily business;
- list the main elements to be reported and the associated timeline;
- understand how to ensure a suitable compliance framework.
Content
- Context and introduction
- Concerned market players
- Scope of reportable cross-border arrangements
- Hallmarks
- Reporting obligations in Luxembourg
Target audience
Operations, compliance and/or tax functions from banks and from insurance companies, as well as asset managers.
Our lead experts
This training will be coordinated by Murielle Filipucci and Pierre Kirsch, Partners at PwC Luxembourg.
With more than 25 years of experience with PwC in international taxation, Murielle, Tax Partner, is acting today as banking tax leader.
She heads a team of 60 professionals specialised in tax consulting and compliance services for the financial services industry including banks, insurance companies, Professionals of the Financial Sector and asset managers.
Murielle also leads the PwC task force focusing on client challenges that result from the automatic exchange of information.
Pierre, Tax Partner, is an authorised manager of PwC Regulated Solutions, overseeing all services related to tax transparency and automatic exchange of information. With over 27 years of experience in the private banking and asset management industries in Luxembourg, Pierre has developed a profound understanding of their internal processes.
He has conducted various tax transparency analyses of the private and corporate client base of several major financial institutions in Luxembourg and abroad. The primary objectives of these analyses were to assess the level of risk posed by non-tax compliant clients and to formulate appropriate and measurable action plans.
