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On 25 May 2018, the Council of the European Union adopted a directive concerning the mandatory automatic exchange of information in the field of taxation, in relation to reportable cross-border arrangements (Council Directive (EU) 2018/822). This EU mandatory disclosure regime, known as the DAC6 Directive, aims to increase transparency by requiring intermediaries and, in certain circumstances, taxpayers, to report cross-border transactions that are deemed to represent aggressive tax planning.

In this article, the authors discuss four examples that intermediaries may encounter in the context of Luxembourg private equity investment structuring.

This article was first published on on 10 November 2020 and a link to the original article can be found here.


Diogo Duarte de Oliveira is a partner in charge of the Tax Department of Baker McKenzie's Luxembourg office. He has over 16 years of experience. Prior to joining Baker McKenzie in 2019, Diogo was tax partner and head of tax at the top-ranked practice of a Benelux leading law firm. He was also an international corporate tax manager with a Big Four audit firm in Luxembourg (and in Mexico City as a secondee).


Olivier Dal Farra is Counsel in the tax group of Baker McKenzie's Luxembourg office. He is specialized in corporate tax and international tax planning. He has more than 10 years of experience in Luxembourg. Before joining the Firm in 2019, Olivier worked as a senior tax manager for an audit firm in Luxembourg and several international law firms in Paris and Luxembourg.