Continuing their open communication policy, the Dutch MDR team released details of the DAC6 reports submitted to the Dutch tax authorities in January and February 2021.
There were 4,429 disclosures made between 1 January 2021 and 28 February 2021. 4,259 of the disclosures were for reports in the historical period from 25 June 2018 until 31 December 2020. Only 170 reports related to new transactions. In total 5035 different hallmarks were reported. 35% of hallmark disclosures related to intra-group cross border transfers, covered by hallmark E3. 25% of hallmarks reported concerned the different characteristics of the C1 hallmarks .Hallmark B2, relating to income conversion accounted for 14% of disclosures.
Below is a summary of the hallmarks that were reported during the period. Some transactions may have contained multiple hallmarks.
A1: Conditions of confidentiality: 5
A2: Fee agreements: 3
A3: Standardised documents or structures: 33
B1: Acquiring loss making companies: 3
B2: Income conversion: 723
B3: Circular transactions: 228
C1a: Deductible cross border payments: 346
C1bi: Low or tax exempts recipients: 316
C1bii: Blacklisted recipient country: 282
C1c: Hybrids: 90
C1d: Preferentially taxed recipients: 268
C2: Same depreciation: 13
C3: Double taxation: 41
C4: Transfer of assets: 382
D1: Undermining reporting obligations: 17
D1: Other: 59
D2: Ownership chains: 25
E1: Unilateral safe harbour rules: 258
E2: Hard to value intangibles: 357
E3: Intra group cross border transfers: 1586
Total hallmarks reported: 5,035
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DAC6 Netherlands: Reporting summary from January to February 2021 is written by VinciWorks for vinciworks.com