F1ANNEX IVHALLMARKS

Annotations:

Part II.Categories of hallmarks

B.Specific hallmarks linked to the main benefit test

1.

An arrangement whereby a participant in the arrangement takes contrived steps which consist in acquiring a loss-making company, discontinuing the main activity of such company and using its losses in order to reduce its tax liability, including through a transfer of those losses to another jurisdiction or by the acceleration of the use of those losses.