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July 9, 2018
2018-5831

European Commission provides examples of hallmarks under EU mandatory transparency rules

On 3 July 2018, the European Commission responded to EY’s request for access to the European Commission document providing examples and origin of the hallmarks with respect to the mandatory transparency rules (Council Directive (EU) 2018/822 of 25 May 2018 amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation in relation to reportable cross-border arrangements). The document was prepared by the Commission department on Taxation and Customs Union in 2017 in response to requests from the European Union Member States for clarification of the hallmarks. This document is attached. It is important to note that the document was discussed on 27 September 2017, while the Directive was adopted on 25 May 2018. Consequently, some of the hallmarks were significantly changed throughout the process. However, the document provides more insights into the intentions behind the hallmarks included in the Directive. A detailed EY Global Tax Alert will be forthcoming.

 
 

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