F1ANNEX IVHALLMARKS

Annotations:

Part II.Categories of hallmarks

E.Specific hallmarks concerning transfer pricing

3.

An arrangement involving an intragroup cross-border transfer of functions and/or risks and/or assets, if the projected annual earnings before interest and taxes (EBIT), during the three-year period after the transfer, of the transferor or transferors, are less than 50 % of the projected annual EBIT of such transferor or transferors if the transfer had not been made.