F1ANNEX IVHALLMARKS
Annotations:
Amendments (Textual)
Part II.Categories of hallmarks
B.Specific hallmarks linked to the main benefit test
2.
An arrangement that has the effect of converting income into capital, gifts or other categories of revenue which are taxed at a lower level or exempt from tax.
Inserted by 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.