On 19 May 2021, BlueBridge presented Part II of our webinar on the DAC6 Intragroup Hallmarks for non-financial corporate groups. In Part II, we explored a series of concrete examples drawn from our experiences and designed to illustrate the real-world application of the DAC6 Intragroup and other corporate Hallmarks, which we had introduced conceptually in Part I of the webinar on 14 April.
To that end, we examined the following three scenarios:
- A corporate group structure with IP held in a low-tax jurisdiction and royalty payments from operating businesses in high-tax jurisdictions
- A Parent corp with an offshore hybrid subsidiary benefitting from the differing jurisdictional treatments of the hybrid
- An asset transfer amongst parties–related and unrelated–located in different jurisdictions with differing treatments of non-DAC6 topics that impact DAC6
If you missed the webinar but are interested in learning more about this particular DAC6 topic:
Written
by Paul Millen
Paul is a first mover and foremost thinker on the impact of the MDRs and DAC6 on the financial services industry, having spoken on the topic at prominent tax conferences in Switzerland and abroad and published detailed analyses in leading periodicals since 2018. As the founder of Millen Tax & Legal GmbH, he advises a range of clients, including banks, trust companies, fund managers and single family offices, on an array of US and cross-border tax and legal matters, most notably FATCA and CRS.