The bill contains several sections that complement and
extend the existing domestic rules on tax transparency and exchange
of information.
On 13 June 2022, the Luxembourg government laid bill no. 8029
(the "Bill") before Parliament. It would
implement into domestic law Council Directive (EU) 2021/514 of 22
March 2021 amending Directive 2011/16/EU on administrative
cooperation in the field of taxation ("DAC
7").
The Bill contains several sections that complement and extend
the existing domestic rules on tax transparency and exchange of
information.
The Bill includes provisions of DAC 7 that expand and help
harmonise the exchange of information between the tax authorities
of different Member States. Notably, a definition has been
established for the term "foreseeable relevance"
(pertinence vraisemblable): requested information is
foreseeably relevant where, "at the time the request is made,
the requesting authority considers that, in accordance with
