F1ANNEX IVHALLMARKS
Annotations:
Amendments (Textual)
Part II.Categories of hallmarks
D.Specific hallmarks concerning automatic exchange of information and beneficial ownership
2.An arrangement involving a non-transparent legal or beneficial ownership chain with the use of persons, legal arrangements or structures:
- (a)
that do not carry on a substantive economic activity supported by adequate staff, equipment, assets and premises; and
- (b)
that are incorporated, managed, resident, controlled or established in any jurisdiction other than the jurisdiction of residence of one or more of the beneficial owners of the assets held by such persons, legal arrangements or structures; and
- (c)
where the beneficial owners of such persons, legal arrangements or structures, as defined in Directive (EU) 2015/849, are made unidentifiable.
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.