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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 transaction must fall within the scope of one of 'hallmarks' in order to be reportable. The explanation and interpretation of the hallmarks is therefore very important.

This edition focuses on Hallmark B.2. Hallmark B.2 concerns conversions of income into capital, gifts or other categories of income that are taxable at a lower rate or are fully tax exempt.