On 19 March 2026, the Luxembourg Parliament adopted the law implementing Council Directive (EU) 2023/2226 of 17 October 2023, also known as DAC8, amending Directive 2011/16/EU on administrative cooperation in the field of taxation. DAC8 applies as from 1 January 2026, with 2026 being the first reporting year.
DAC8 pursues two key objectives:
(i) expanding tax transparency and the exchange of information by introducing new categories of reportable transactions, in particular those involving crypto‑assets; and
(ii) updating and consolidating the various information‑exchange mechanisms introduced through successive amendments to the DAC framework.
In this Alert, our Tax Partner and Head of Transfer Pricing, Oliver R. Hoor, and our Chief Knowledge Officer, Marie Bentley, provide an overview of DAC8’s key implications.