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.
Robert Jan Meindersma
Director, PwC Netherlands
Tel: +31 (0)88 792 61 86
Partner, International Business Taxation & Tax Policy, PwC Austria
Tel: +43 1 501 88-3431
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