A cross-border arrangement becomes reportable only if certain characteristics or features are present, referred to as ‘hallmarks.’ Since most EU Member States have transposed definitions of hallmarks into their domestic mandatory disclosure regime in line with DAC6, we will provide an overview in which we outline the different hallmarks as defined in DAC6.
- Main Benefit test
- The following categories of hallmarks will be discussed below:
Source: tax-model.com
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