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Luxembourg: EU directive (DAC 6), disclosure of cross-border arrangements

Luxembourg: Disclosure of cross-border arrangements

Luxembourg’s government on 26 July 2019 approved a bill for transposition of an EU Directive on administrative cooperation in the field of taxation (DAC 6)—also known as the EU Directive implementing mandatory disclosure rules for intermediaries (MDR). The bill must now be submitted to parliament and complete the legislative process.


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The legislation would introduce a new requirement for EU intermediaries (and for taxpayers, in some instances) to disclose certain reportable cross-border arrangements to the Luxembourg tax authorities and then for this information to be shared with other EU tax authorities.

Beginning 1 July 2020, DAC 6 requires information on cross-border arrangements to be reported within 30 days. The countdown begins from whichever occurs first:

  • The day after the reportable cross-border arrangement is made available/ready for implementation
  • The day when the first implementation step is made

However, there may be retroactive application of cross-border arrangements when the first step was implemented between 25 June 2018 (the entry into force date for DAC 6) and 1 July 2020 (the application date of DAC 6). For these purposes, the related information must be reported by 31 August 2020.

Read a July 2019 report prepared by the KPMG member firm in Luxembourg

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