DAC 6
Council Directive (EU) 2018/822 amending Directive 2011/16/EU (“DAC 6”) is currently the hot topic in tax that will impact very shortly the professionals of the financial sector and their clients.
In a tax environment becoming more and more transparent, the DAC 6 regulation introduces the mandatory exchange of information for reportable cross-border arrangements within the EU.
Indeed, this regulation requires from intermediaries such as banks, asset managers, life insurance companies, advisors to ensure appropriate processes and procedures 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 DAC 6. Some of the hallmarks should be corroborated with a main benefit test with respect to the tax advantage of the arrangement.
Depending on its DAC 6 qualification (Promoters, Service Providers, Taxpayers) and the other actors involved in the arrangement structures, the concerned market players may have reporting obligations regarding preexisting and new arrangements.
This webinar, in 2 parts, will cover the above technical and operational DAC6 elements supported by real-life examples, to provide the participants with the must-have insight to understand and anticipate the upcoming DAC6.
29 September 2020: 10am - 12pm - Part 1 & 8 October 2020: 10am - 12pm - Part 2 (EN)
1 October 2020: 10am - 12pm - Part 1 & 7 October 2020: 10am - 12pm - Part 2 (DE)
5 October 2020: 2:30pm - 4:30pm - Part 1 & 12 October: 2:30pm - 4:30pm - Part 2 (FR)
11 November: 2:30pm - 4:30pm - Part 1 & 17 November: 2:30pm 4:30pm - Part 2 (EN)
Price: 600.00 € (300€/part)
Duration: 2h
Language: English, also available in French and German
Number of participants: max. 20
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 organization 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 & 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, asset managers and insurance undertakings.
Our lead experts
This training will be given by Murielle Filipucci, Partner and Amandine Horn, Director at PwC Luxembourg.
Murielle Filipucci is a Partner in the PwC Luxembourg’s tax practice, acting as Banking Tax Leader.
With more than 23 years of experience with PwC in International Taxation, she is acting today as Banking Tax Leader and Italy Country Program Leader.
She leads a team of 60 professionals specialized in tax consulting and compliance services for the FS industry including banks, insurance companies, professionals of the financial sector and asset managers.
She leads the PwC task force focusing on client challenges resulting from the automatic exchange of information. She set up the PwC Professional of the Financial Sector, PwC Tax Information Reporting Sàrl, PwC TIR Sàrl, dedicated to tax information reporting solutions where she is an executive member of the Board.
Amandine Horn is a Director in the Luxembourg Financial Services Tax Practice. She has over 14 years experience in international tax consulting for international financial groups such as banks, insurance undertakings and investment management firms. During this period, she provided tax consulting services in the scope of international tax reorganisations, financial transactions and tax due diligence.
Amandine also developed an expertise in operational tax compliance for financial services market players, notably on exchange of information and withholding tax topics.
Amandine notably focused on exchange of information implementation and healthcheck projects (EUSD/FATCA/CRS), and has been working for numerous banks supporting them regarding Qualified Intermediary (“QI”) matters. Due to her long lasting active involvement in such projects, she has gained not only deep tax technical expertise but also a deep insight on the organisation of international banks and other types of financial institutions.
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