LIVE ONLINE WEBINAR - DAC 6 Directive: Practical Workshop | New Course
- Λογιστικά/ Έλεγχος/ Φορολογικά - Νομοθεσία, Νομική & Δικηγόροι
ΠΕΡΙΓΡΑΦΗ
Due to this fiscal crisis, international tax issues have never been as high on the political agenda as they are today. The Directive (EU) 2018/822 represents the 6th modification of DAC, and it reflects new initiatives in the field of tax transparency at the level of the EU, through the introduction of an early warning mechanism for tax avoidance schemes.
DAC 6 sets out a minimum standard which means that some member states might go further than others. DAC 6 leaves it opens for member states to implement penalties against the violation of national rules that implement DAC 6. The penalties should be effective, proportionate, and dissuasive. If the penalties do not fulfil the requirement for being effective proportionate and dissuasive, there is a risk that intermediaries and relevant taxpayers report information about arrangement that is subsequently discarded in order to avoid sanctions for under-reporting or non-reporting.
ΣΚΟΠΟΣ ΣΕΜΙΝΑΡΙΟΥ
The purpose of this course is to investigate whether the Cyprus implementation of the DAC 6 seems a proportionate measure to prevent tax avoidance and evasion in the form of aggressive tax planning. In order to describe the Cyprus implementation, the course will consider the Cyprus government’s interpretation and approach of DAC 6. Since Cyprus have not yet implemented the national legislation on the directive DAC 6, there is limited available material.
The course will use DAC 6 and preparatory work to describe the Swedish implementation. Other than DAC 6 and preparatory work, the course will use opinions by experts and doctrines in order to gather the material needed to be able to analyse if Cyprus’ implementation is compatible with the proportionality principle. The course will further use case law by the CJEU in order to describe their view on the proportionality principle.
ΣΕ ΠΟΙΟΥΣ ΑΠΕΥΘΥΝΕΤΑΙ
- Accountants
- Auditors
- Tax advisors on Direct Taxation matters (which are governed by the relevant Directive / legislation)
- Finance Directors
- Chief Financial Officers
- Lawyers
- Administrative Service Providers
- Trustees
- Relationship managers employed by firms which fall under the provisions of this Directive / legislation
ΠΕΡΙΣΣΟΤΕΡΕΣ ΠΛΗΡΟΦΟΡΙΕΣ
Training Outline
Introduction
- BEPS Action 12 on MDR (DAC6 Template)
- The Function of MDR
- The Design of MDR
- Comments
- The EU Directive on MDR (DAC6)
Directive on Administrative Co-operation (DAC 6)
- Purpose of DAC 6
- DAC 6
- Introduction
- Definitions
- Who bears the burden of disclosure
- What to report and When
- Hallmarks
- A Hallmark A: generic hallmarks linked to the main benefit test 7
- Hallmark B: specific hallmarks linked to the main benefit test
- Hallmark C: specific hallmarks related to cross-border transactions
- Hallmark D: specific hallmarks concerning automatic exchange of information and beneficial ownership
- Hallmark E: specific hallmarks concerning transfer pricing
Cyprus implementation
- Introduction
- Who bears the burden of disclosure
- Penalties
- Consequences
- Criticism
- Summarized analysis
The Principle of proportionality
- Introduction
- The CJEU’s view on proportionality
- Summarized analysis
- Conclusions
Human Rights Perspectives on Mandatory Disclosure Rules on Intermediaries
- Taxation and Human Rights
- General Considerations
- Human Rights in the EU
- DAC 6 and Human Rights
- Right to Property
- Right to Privacy and Related Rights
- Right to Fair Trial and the Right against Self Incrimination
Conclusion
Πληροφορίες Εκπαιδευτή
Αναλυτικό Κόστος Σεμιναρίου
- € 180.00
- € 0.00
- € 34.20
- € 180.00
ΠΡΟΓΡΑΜΜΑ ΣΕΜΙΝΑΡΙΟΥ
Τρίτη - 01 Ιουν 2021
Ώρα
09:00 - 15:00
ΕΚΠΑΙΔΕΥΤΗΣ:
Δημήτρης ΣαββίδηςΤοποθεσία:
OnLine Virtual Classroom