Dac6

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.

Indeed, 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 its 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.

By the end of the course, participants will be able to:

• gain an overview of the directive;
• understand the reporting obligations;
• understand the mechanism of the hallmarks.

• Context and introduction
• Concerned market players
• Scope of reportable cross-border arrangements
• Hallmarks
• Reporting obligations in Luxembourg

An attendance certificate will be sent to participants.

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. She has set up the PwC Professional of the Financial Sector Tax Information Reporting sàrl dedicated to tax information reporting solutions where she is a board executive member.

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.