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In our DAC6 Pulses we keep you informed about the implementation of EU MDR (aka DAC6) in the different EU member states. In addition, we periodically explain one of the key features (‘hallmarks’) of DAC6. A hallmark is defined as a characteristic or feature of a cross-border arrangement that presents an indication of a potential risk of tax avoidance, as listed in Annex IV of the EU Directive.

This edition focuses on Hallmark C2. An arrangement is reportable under C2 if deductions for the same depreciation on the asset are claimed in more than one jurisdiction.