What is the impact of DAC6 on the popular structures used by HNWI: private holding company, trusts, Stiftung, Unit-linked life insurance contract, donation of a securities portfolio, use of offshore companies, Luxembourg dedicated fund (SICAV SIF), transfer of financial assets to a foreign bank. For each structure, what are the possible hallmarks? Who is an intermediary? What is the “first step of implementation” of the structure?

DAC6 rules in the light of the recent administrative instructions: Germany (2 March 2020), Luxembourg (19 August 2020), UK (HMRC guidance 13 August 2020), Belgium (FAQ 15 June 2020), France (administrative commentary 29 April 2020),

What is the impact of DAC6 on the popular structures used by HNWI: private holding company, trusts, Stiftung, Unit-linked life insurance contract, donation of a securities portfolio, use of offshore companies, Luxembourg dedicated fund (SICAV SIF), transfer of financial assets to a foreign bank. For each structure, what are the possible hallmarks? Who is an intermediary? What is the “first step of implementation” of the structure?

DAC6 rules in the light of the recent administrative instructions: Germany (2 March 2020), Luxembourg (19 August 2020), UK (HMRC guidance 13 August 2020), Belgium (FAQ 15 June 2020), France (administrative commentary 29 April 2020),