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By Romain Tiffon, Tax Partner with ATOZ Tax Advisers (Taxand Luxembourg) *
On 21 June 2017, the European Commission published a proposal (the “Proposal”) for a Council directive that aims at amending Directive 2011/16/EU by imposing an obligation on intermediaries to report any cross-border arrangement which contains one or more of the “hallmarks” set forth in the Proposal to the competent tax authority so that the latter be in a position to automatically exchange that information with other EU member States (the “Member States”).
1. Background
It is now well established that one of the key political priorities of the European Union (the “EU”) is to tackle tax avoidance and evasion so as to create a fairer...
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