On 24 July 2025, the Luxembourg government released a draft law aimed at implementing Council Directive 2023/2226 dated 17 October 2023, the so-called "DAC8", amending Directive 2011/16/EU on administrative cooperation in the field of taxation (DAC).
DAC8 pursues two major objectives:
1. Expanding the scope of transparency and tax information exchange by including new types of reportable transactions, particularly those involving crypto-assets.
2. Updating and consolidating the various tax information exchange mechanisms introduced through successive amendments to DAC. In this regard, DAC8 notably:
- Introduces new exchange of information on income derived from life insurance products;
- Introduces new exchange of information on certain advance tax rulings related to individual taxpayers;
- Allows the use of exchanged information for non-tax purposes;
- Modifies DAC6 in relation to the professional secrecy of intermediaries;
- Amends DAC7 in relation to the volume of data to be transmitted; and
- Updates country-by-country reporting requirements.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
