ΠΕΡΙΓΡΑΦΗ

This seminar is addressed to professionals who need to be able to identify who is an intermediary and which arrangement is considered as a cross border arrangement entailing DAC6 obligations so as to timely inform their clients of such obligations, avoiding thus the imposition of penalties and also safeguarding the DAC6 compliance of their clients or their business. The aforementioned professionals are required to have a comprehensive understanding of DAC6 practices and procedures and be in a position to perceive the full picture when dealing with an arrangement. Therefore, it is imperative that professionals have the required knowledge and awareness in order to ensure compliance in a highly complex, rapidly changing, cross-border environment. 

The offered Professional Training Course has been approved by the Human Resources Development Authority of Cyprus (HRDA) & contributes to Continuing Professional Development for 7 CPD Units.

ΣΕ ΠΟΙΟΥΣ ΑΠΕΥΘΥΝΕΤΑΙ

This program is specifically designed for professionals who would like to become familiar with the essential concepts and principles of DAC6 in order to gain a better understanding of the field and correctly interpret the transactions they may potentially face on a daily basis in their working environment.

More specifically:

• corporate service officers;
• accountants;
• tax and financial advisors;
• banking consultants;
• in-house legal team;
• agents;
• trustees;

ΠΕΡΙΣΣΟΤΕΡΕΣ ΠΛΗΡΟΦΟΡΙΕΣ

MODULES 

PART A: Overview 

• Scope of the DAC6 Directive 
• Intermediaries 
• Relevant Taxpayer 
• Reportable Cross-border Arrangement

PART B: The Hallmarks and the Main Benefit Test (MBT) 

• Overview of the Generic hallmarks and Specific hallmarks 
• Main Benefit Test (MBT) 

Hallmark A - Generic Hallmarks Linked to MBT 

• A.1 -The “Confidentiality” hallmark 
• A.2 -The “Success fee” hallmark 
• A.3 -The “Standardized documentation” hallmark 
• Practical Questions & Examples

Hallmark B - Specific Hallmarks Linked to MBT 

• B.1 -The “Loss making company acquisition” hallmark 
• B.2 -The “Converting income scheme” hallmark
• B.3 -The “Circular transactions” hallmark 

Practical Questions & Examples 

Hallmark C - Specific Hallmarks Related to Cross-Border Transactions 

• C.1 – The “Deductible cross-border payments” hallmark 
• C.2 -The “Double depreciation” hallmarks 
• C.3 -The “Double relief” hallmarks 
• C.4 -The “transfer of assets” hallmark 
• Practical Questions & Examples

Hallmark D - Specific Hallmarks concerning automatic exchange of information and beneficial ownership 

• D.1 - The “No CRS Reporting” hallmark 
• D.2 - The “Non-transparent Beneficial Ownership chain” hallmark 
• Practical Questions & Examples

Hallmark E - Specific Hallmarks concerning Transfer Pricing 

• E.1 - The “Unilateral safe harbour” hallmark 
• E.2 - The “Hard-to-value Intangibles” hallmark 
• E.3 - The “Business restructuring” hallmark 
• Practical Questions & Examples

PART C: Information to be reported 

PART D: Timing aspects PART E: Penalties for non-compliance

Trainer: Mr Marios Palesis (Kinanis LLC, Partner)

Marios is a qualified Accountant and a Fellow member of Association of Certified Chartered Accountants (FCCA), as well, as a member of the Institute of Certified Public Accountants of Cyprus, member of Advanced Diploma in International Taxation (ADIT) and International Tax Affiliate of the Chartered Institute of Taxation (CIOT). Marios has significant experience in Transfer Pricing and international tax planning. He is servicing clients in Cyprus, Malta, Eastern Europe and in other jurisdictions around the globe. His focus is on financial transactions and digital business