The Luxembourg law of 25 March 2020 implementing Council Directive 2018/822/EU of 25 May 2018 (the DAC 6 Law), which entered into force on 1 July 2020, requires intermediaries and, in some cases, taxpayers to disclose to the tax authorities information on certain cross-border arrangements that might be viewed as aggressive tax planning schemes.

An arrangement is reportable if:

  • it qualifies as a cross-border arrangement, and
  • there are indications of a potential risk of tax avoidance, known as “hallmarks”. Some hallmarks will only trigger a reporting obligation if the arrangement also meets the so-called “main benefit test”.

The reporting obligation will start as from 1 January 2021, and needs to be met within set deadlines. After reports have been filed, an automatic exchange of information will take place between the tax authorities of all EU Member States.

Our experts from Arendt Regulatory & Consulting (ARC), the regulatory consulting expertise of Arendt can help you know to what extent DAC 6 concerns your company, understand your DAC 6 obligations, be advise on how to efficiently implement DAC 6 compliance and to file your DAC 6 report.

Table of contents:

- Reporting on aggressive tax planning arrangements

- Who is concerned?

- Is your transaction reportable?

- A la carte services

- Contact details


For more information, contact us at

Related Content

Arendt Regulatory & Consulting SA

41A, Avenue JF Kennedy L-2082 Luxembourg

T (352) 26 09 10 1
F (352) 26 09 10 7750


Would you like to configure your browsing experience at

Let us know your profile and favourite topics

You are

Banking and Financial Services


Fund and Asset management

Private Clients
Public Sector