Webinar Recap: DAC6 for Corporates: Illustrative Examples of the Intragroup Hallmarks

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:

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