“By 31 December 2023, 2,806 reports on cross-border tax arrangements had been submitted to the Luxembourg tax administration and uploaded to the Central Repository set up by the European Commission,” finance minister Gilles Roth (CSV) said in a parliamentary response on 12 March 2025. Library photo: Eva Krins/Maison Moderne

“By 31 December 2023, 2,806 reports on cross-border tax arrangements had been submitted to the Luxembourg tax administration and uploaded to the Central Repository set up by the European Commission,” finance minister Gilles Roth (CSV) said in a parliamentary response on 12 March 2025. Library photo: Eva Krins/Maison Moderne

As part of the Dac6 directive, 2,806 reports on cross-border tax arrangements were submitted to the Luxembourg tax administration from 2021 to 2023. The five countries that submitted the most tax arrangements were Belgium, France, Germany, the Netherlands and Italy.

The Dac6 directive, which introduces an automatic and mandatory exchange of information on cross-border tax arrangements, was transposed in Luxembourg by the law of 25 March 2020, finance minister  (CSV) explained on 12 March in response to a submitted by MP (Piraten).

The first automatic exchange of information under DAC6 took place on 28 April 2021. “By 31 December 2023, 2,806 reports on cross-border tax arrangements had been submitted to the Luxembourg tax administration and uploaded to the Central Repository set up by the European Commission. These tax arrangements concern either one or more member states. Some only concern Luxembourg and a third country.”

The five countries that have submitted the most cross-border tax arrangements from 2021 to 2023 are Belgium (total of 377), France (339), Germany (299), the Netherlands (197) and Italy (101).

“By 31 December 2023, the tax administration had downloaded 9,521 notifications of cross-border tax arrangements, which Luxembourg had indicated as the member state concerned and which had been filed in other member states, from the Central Repository to integrate them into its national database,” added Roth. A breakdown by country cannot be provided as the authorisation of member states is required.

For now, these reports are only analysed at the request of a tax office for a certain taxpayer, said Roth. “In the future, this information should be made systematically available to the tax offices and can also be used together with other data to carry out risk analyses and, in addition, feed into a general risk management solution of the tax administration.” Tracking a potential tax loss to a specific cross-border tax arrangement is not possible using Dac6 data.

The tax administration also carries out quality control checks, checking the completeness of the reports submitted here in Luxembourg and ensures that all information on cross-border tax arrangements, noted the parliamentary response. The information exchange and tax withholding division of the tax administration has a dedicated team of five people responsible for the information on cross-border tax arrangements. This is “sufficient” for current needs, but the team may be expanded in the future.

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