DAC6 in a Selection of EU Member States: The Practical Application of the Main Benefit Test and Its Hallmarks

In this article, the authors provide a survey of the practical application of the DAC6 main benefit test and its hallmarks in Belgium, France, Germany, Ireland, Luxembourg, the Netherlands, Portugal and Spain. They examine the general features of this test and of its related hallmarks, followed by specificities of the interpretation of their practical application by the competent authorities of those countries, whenever applicable, considering typical structures.