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#1 2019-12-03 20:26:21


Are general partners intermediaries under DAC6

A GP manages the partnership.
Is this managing identical to the definition of the term Intermediary:

"design market organize,
make available for implementation or
manage the implementation of a cross-border reportable arrangement."

This part of the definition is the Promoter alternative. Is the GP a promoter ?
Or is the GP more akin to a service provider that knowingly "aids in the implementation".

Does the GP only in certain circumstances become an Intermediary, when managing in a certain way ?


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