What work are we going to provide to the client? [max. 10 sentences]
What are the direct tax risk areas (TP, permanent establishment, CFC, beneficial ownership and GAAR sensitive areas) identified when scoping the work for this particular project and/or client? [max. 10 sentences]
Does the tax arrangement concerns at least the territory of 1 EU-member state?
Does the arrangement fall into one or more of the 5 categories of hallmarks?
Did TPA design, market, organize, make available for implementation OR manage the implementation of the tax arrangement?
Could the employee of TPA know or could be reasonably expected to know about the background of clients' request for these services?
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