The mandatory disclosure regime (DAC6): A series of practical case studies


We’re taking our ATOZ Briefings on-line!

ATOZ Briefings are seminars offered by ATOZ to ensure that our clients are ahead of the curve on specific topics which may affect their areas of business.

In these extraordinary times, we stand by our clients and adapt to a new reality, keeping everybody informed through a series of hybrid briefings on current tax topics: you will be able to choose between attending physically (following COVID-19 health and safety regulations) and watching the live streaming from your home or office.

Oliver R. Hoor will therefore be hosting a series of Briefings, over the next few weeks, partnering with Legitech.

This webinar, taking place on 22 October 2020 at 10:30AM CET, is entitled “The mandatory disclosure regime (DAC6): A series of practical case studies”.


On 1 July 2020, the mandatory disclosure regime (MDR) entered into force with first reporting deadlines set at the beginning of 2021. With few months left in 2020, intermediaries and taxpayers have to urgently prepare for the new reporting obligations in order to mitigate the risk of penalties. As the MDR applies with retroactive effect, cross-border arrangements implemented since 25 June 2018 have to be reviewed “now”.

However, how are reportable cross-border arrangements determined? How should some of the more ambiguous hallmarks be interpreted? And, what is a reasonable approach towards the interpretation of the main benefit test (MBT)?

This is the second of two briefings on the MDR (which will be simultaneously streamed online) that focuses on practical case studies. While the briefing is based on the Luxembourg implementation of DAC6 (which is largely a copy/paste of the Directive), given that most EU Member States adhered to the hallmarks and the MBT as provided under DAC6, the content of this briefing should also inform the interpretation of DAC6 across Europe.



  • Introduction
  • How to manage reporting obligations in practice
  • Practical case studies
    1. The Luxembourg real estate fund
    2. The foreign private equity fund
    3. The multinational group
    4. The insurance company
  • Concluding remarks

Please note that space is limited due to COVID-19 but you can attend this event from your home/office thanks to a live streaming.

Register here

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