DAC6: Interpretation of the Hallmarks and the Main Benefit Test in Belgian and International Tax Practice 

The Belgian tax authorities have announced that they will be carrying out the first DAC6 audits as from September 2022. In this article, the author focusses on the interpretation of reportable arrangements, as well as the impact of DAC6 on well-known planning structures in the Belgian and international tax practice (for example, arrangements involving the use of holding vehicles, fund structures, management incentive schemes and corporate restructurings).