Investment Fund Managers, assess the DAC6 impacts on your activities!

As you probably know, the law of 25 March 2020 implementing Council Directive 2018/822/EU of 25 May 2018 (the “DAC 6 Law”), in force since 1 July 2020, requires certain intermediaries and relevant taxpayers to report cross-border tax arrangements implemented on or after 25 June 2018 to the Luxembourg tax authorities (the “LTA”).

An arrangement becomes reportable if:

Starting 1 January 2021*, reporting obligations to the LTA apply both for reportable cross-border arrangements for which the first step of implementation was taken during the period 25 June 2018 – 30 June 2020 (reporting required by 28 February 2021), and for reportable cross-border arrangement implemented on or after 1 July 2020 (from 1 January 2021, reporting required within 30 days).

The DAC 6 Law imposes a fine of up to EUR 250,000 per arrangement in the event of non-compliance with these reporting obligations (i.e. late or incomplete reporting, or failure to report).

How can Arendt help you?

As an IFM, you could be an intermediary, a relevant taxpayer, or both. Should you report all of the arrangements you participate in? What information should you give the LTA? We can help answer these questions by assisting you with:

Please do not hesitate to contact our experts at

* Due to the COVID-19 pandemic, an agreement has been reached at EU level to extend the deadlines for the reporting of information provided for in Directive 2018/822/EU by 6 months (i.e. reporting obligations will begin as from 1 January 2021). The Luxembourg government’s bill of law 7625 is expected to be voted through in the next few days to implement these deadline extensions.

Documents about

2020.07.23 – ARC update – Investment Fund Managers, assess the DAC6 impacts on your activities

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Contact an expert

Yann Fihey

Partner ARC

Bénédicte d’Allard

Senior Manager