DAC6 Pulse - Hallmark of the Month: E.3

29/11/19

In the first DAC 6 Pulse we have updated you on the status of the implementation of DAC6 in the various EU member states, and explained to what extent the scope of DAC6 in the various countries corresponds to the DAC6 guideline.

A transaction must fall under one of the hallmarks in order to fall under the reporting obligation. The explanation and interpretation of the hallmarks is therefore very relevant. For that reason, we will regularly publish extra Pulse-editions in which a specific hallmark is discussed.

This edition focuses on hallmark E.3. In short, hallmark E.3 concerns internal reorganisations within the group, as a result of which the projected EBIT of the transferring entity or the acquiring entity, measured over a period of three years, decreases by more than 50%. Read more on the hallmark of the month. 

Contact us

Edwin Visser

Partner, PwC Netherlands

Tel: +31 (0)88 792 36 11

Robert Jan Meindersma

Director, PwC Netherlands

Tel: +31 (0)88 792 61 86

Mary Psylla

Partner, Tax & Legal Leader, PwC Greece

Tel: +30 210 6874543

Richard Jerabek

Partner, International Business Taxation & Tax Policy, PwC Austria

Tel: +43 1 501 88-3431

Follow us