The new mandatory disclosure regime (DAC 6)

• Purpose and design principles of the mandatory disclosure regime
  

• Key features of the mandatory disclosure regime
  

• Analysing the hallmarks that may trigger reporting obligations
  

• The importance of the main benefit test (“MBT”) when determining reportable cross-border arrangements
  

• Considerations regarding the links between the MBT and anti-abuse legislation

• How to prepare for and manage reporting obligations in practice (intermediaries vs. taxpayers)

• Intermediaries navigating between penalties for non-compliance and penalties for the violation of professional secrecy