Council Directive (EU) 2018/822 of 25 May 2018 has been published in the Official Journal of the EU. The Directive provides for the reporting of potentially aggressive cross-border tax-planning arrangements. The reporting obligation generally applies to intermediaries that design, market, organize, or manage the implementation of a reportable cross-border arrangement, such as accountants, tax advisors, notaries, banks, etc. However, the reporting obligation may be shifted to a taxpayer in cases where an intermediary is prevented by law from reporting the info (legal professional privilege) or where there is no intermediary because, for instance, the taxpayer designs and implements a scheme...