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:

A2: Fee agreements: 3 

A3: Standardised documents or structures: 33 

B1: Acquiring loss making companies:

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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