On 21 March 2020, the Luxembourg parliament passed the law implement DAC6. With less than 2 months until the mandatory disclosure regime (MDR) enters into force, intermediaries and taxpayers have to urgently prepare for the new reporting obligations in order to mitigate the risk of penalties. As the MDR applies with retroactive effect, cross-border arrangements implemented since 25 June 2018 have to be reviewed “now”.
However, how are reportable cross-border arrangements determined? How should some of the more ambiguous hallmarks be interpreted? And, what is a reasonable approach towards the interpretation of the main benefit test?
This is the second webinar on the MDR that focuses on practical case studies that should help practitioners to assess potential reporting obligations and to move towards DAC6 readiness.
While the webinar is based on the Luxembourg implementation of DAC6 (which is largely a copy/paste of the Directive), given that most European Member States adhered to the hallmarks and the MBT as provided under DAC6, the content of the webinar should also inform the interpretation of DAC6 across Europe.