ARTICLE · 02 FEBRUARY 2022

DAC6 And Hallmark E1 – Use Of Unilateral Safe Harbour Rules In Cyprus

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The purpose of this tax bulletin is to shed some light on the use of unilateral safe harbour rules in Cyprus and specifically as to when an arrangement becomes reportable for DAC6 purposes for meeting the requirements of Hallmark E1.

CyprusTax

Marios Palesis

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Hallmark E1

According to the provisions of the sixth amendment of the Directive for Administrative Cooperation in the field of Taxation (DAC6) and the implementing Cyprus legislation, any cross-border arrangement taking place from 25thJune 2018 and onwards, which meets the specific characteristics and requirements of a Hallmark will be considered as a reportable transaction.

A reportable cross-border arrangement is considered to be put into effect at the date:

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DAC6 And Hallmark E1 – Use Of Unilateral Safe Harbour Rules In Cyprus

Hallmark E1

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