Anticipate the implementation of the DAC 6

Extrait 

The DAC 6 incorporates a broad concept of intermediary, as regards mainly, although not exclusively, professionals in tax consultancy.

This includes both intermediaries who assume a primary position or who control the arrangement and others who assume partial tax consulting.

The former, who we could classify as promoters of the arrangement, are defined as “any person who designs, markets, organises or makes available for implementation or manages the implementation of a reportable crossborder arrangement” (section 21 of art. 3 of the Directive 2011/16). As we have just mentioned, this definition, by its scope, also includes entities or
professionals not directly connected to tax consultancy, financial institutions and insurance companies [...]

Anticipate the implementation of the DAC 6
PDF gratuit | 15 pages | Juillet 2019