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Regulatory Blog

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CJEU clarifies the scope of client-attorney privilege on tax matters in Luxembourg
On 26 September 2024, the Court of Justice of the European Union issued its judgement in case C-432/23 in which it reinforced the principle of client-attorney privilege in the context of the exchange of information with the tax administration, limiting the extent to which lawyers can be compelled to disclose confidential client information under the Administrative Cooperation Directive (Directive 2011/16), commonly referred to as DAC.
EU updates its tax blacklist
On 17 October 2023 the European Council made significant adjustments to its list of non-cooperative jurisdictions for tax purposes.
European Council extends cooperation initiatives on crypto-assets and wealthy individuals in taxation, relevant to MiCA and DAC8
On 16 May 2023, the Council of the European Union issued a press release announcing that it has reached a general approach on the amendments to the directive on administrative cooperation in taxation, focussing on the reporting and automatic exchange of information related to crypto-asset transactions and advance tax rulings for high-net-worth individuals.
Exploring the implications of the BVI’s inclusion on the EU's list of non-cooperative jurisdictions
The recent inclusion of the British Virgin Islands on the EU’s blacklist has caused many to question the legal and regulatory implications. The primary principle to note is that, outside of the EU, EU law has minimal direct application and therefore this temporary inclusion will not bring about any immediate negative consequences for BVI funds or BVI managers.
Upcoming deadline for Country-by-Country reporting in Cyprus
The submission of the Country-by-Country reporting/notification obligations in Cyprus is due by 31 December 2022.
Harneys develops DAC6 Toolkit – automated assessments and easy reporting
On 31 January 2022, the Cyprus Tax Department (CTD) finally brought the regime providing for the mandatory reporting of reportable cross border arrangements (RCBAs), known as DAC6, into force in Cyprus. Up until this point, various transitional provisions and safe-harbours had been in place to soften the introduction of the regime.
DAC6: Cyprus Guidance now in English
As mentioned in our previous post, the Cyprus DAC6 Guidance has been with us since October 2021, but has to date been available only in Greek (publicly at least).
Important update: DAC6 now in Cyprus
On 31 January, the Cyprus Tax Department (CTD) finally brought the regime providing for the mandatory reporting of reportable cross border arrangements (RCBAs), known as DAC6, into force in Cyprus. Up until this point, various transitional provisions and safe-harbours had been in place to soften the introduction of the regime.
EU priorities regarding taxation measures in 2022
In a statement that resembled the type of new year wishes that are normally reserved for politicians to make after the start of a new year, the EU Parliament and Commission (through ECOFIN) have already indicated what their priorities will be for 2022. We can expect the French presidency of the Commission to be particularly proactive in pushing these priorities forward in the first half of the year.
Cyprus further extends the DAC6 deadline
On 22 November 2021, the Cyprus Tax Department announced an additional extension for the submission of information on DAC6. The new deadline for filing without administrative fines for late submission on DAC6 is 31 January 2022.
Cyprus issues DAC6 Guidance Notes
On 1 November 2021, the Cyprus Ministry of Finance issued a Decree based on article 22Z on Administrative Cooperation in the Sector of Taxation Amending Law of 2021 (Κ.Δ.Π. 438/2021) (the Decree) with regards to the implementation and regulation of issues arising from the transposition of the DAC6 Directive into national law earlier this year.
Cyprus Tax Department publishes updated XML Schema for DAC6 reporting
The Cyprus Tax Department (CTD) has advised that as of 5 August 2021, a new XML Schema has entered into force, which should be used by intermediaries and taxpayers when submitting information for the purposes of DAC6.
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