Luxembourg: FAQ on mandatory disclosure rules (DAC6)

FAQ on mandatory disclosure rules in relation to cross-border arrangements (DAC6)

FAQ on mandatory disclosure rules in relation to cross-border arrangements (DAC6)

The tax authority on 4 May 2022 published on its website a new “frequently asked question” (FAQ) on the mandatory automatic exchange of information in relation to cross-border arrangements (DAC6).

The new FAQ recaps and completes practical definitions which were already available in previous guidelines and also provides some useful clarifications on technical aspects of the DAC6 rules, namely on certain hallmarks and the main benefit test.

KPMG observation

Subject to further analysis and clarifications, the broad interpretation of some DAC6 concepts and hallmarks by the Luxembourg tax authorities might lead to increased reporting in the coming months and years.

Read a May 2022 report prepared by the KPMG member firm in Luxembourg

 

The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.