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Philippe Lion

Philippe Lion is a senior counsel in the Tax Practice Group in the Brussels office and former Head of the EMEA Tax Practice of the Firm, a position which he held between 2010 and 2016. Prior to that, he headed the EMEA Tax Transaction practice for a period of three years. Before joining Baker McKenzie in 2003, Philippe worked for more than 10 years in the tax department of one of the Big 4 (PWC), including an 18 months secondment in their Frankfurt office. Since more than 10 years, Philippe is a lecturer on International Tax Planning at the Solvay Brussels School of Economics and Management.

On 25 May 2018, the Council of the European Union adopted a directive on the mandatory disclosure and exchange of cross-border tax arrangements. This is the sixth update of the Directive on Administrative Cooperation, therefore referred to as ‘DAC6’ and the disclosure regime is now live.
Under the new rules, intermediaries such as lawyers, tax advisors, and accountants that design, promote or implement certain ‘arrangements’, or that provide advice in relation to such arrangements, are required to report them to tax authorities.

Following a recent announcement of the European Commission’s proposal for a three-month deferral of reporting deadlines under the new DAC6 mandatory disclosure regime in the EU and UK, the Committee of the Permanent Representatives of the Governments of the Member States to the European Union (COREPER) has now reached an agreement on a revised proposal which could possibly defer the reporting deadline for six months. On the basis that the draft Directive, once approved, may be adopted at the discretion of each member state, it is imperative that businesses do not delay in preparing to meet their existing compliance obligations should reporting dates not be deferred (or not be deferred in all Member States where they operate).