On May 25 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.
Luxembourg implementation of the DAC6 Directive
DAC6 Law and Luxembourg private equity structures
- Example A: Debt financing
- Example B: Equity funding (Luxembourg classes of shares)
- Example C: Carried interest and management incentive plans
- Example D: Corporate reorganisations
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This article was first published on www.itrinsight.com on 10 November 2020 and a link to the original article can be found here: https://www.internationaltaxreview.com/article/b1p5k7kbcwj5c6/mandatory-disclosure-rules-dac6-a-look-at-private-equity-investment-in-luxembourg. This article is reproduced on InsightPlus with permission.