Photo from: KINANIS LLC – 5th Photography Competition 2023 – Theme: “LIFE” – Photographer: Alexandros Apostolou – Photograph Title: ‘Foggy morning‘

This seminar is addressed to professionals who need to be able to identify who is an intermediary and which arrangement is considered as a cross border arrangement entailing DAC6 obligations so as to timely inform their clients of such obligations, avoiding thus the imposition of penalties and also safeguarding the DAC6 compliance of their clients or their business. The aforementioned professionals are required to have a comprehensive understanding of DAC6 practices and procedures and be in a position to perceive the full picture when dealing with an arrangement. Therefore, it is imperative that professionals have the required knowledge and awareness in order to ensure compliance in a highly complex, rapidly changing, cross-border environment.


This program is specifically designed for professionals who would like to become familiar with the essential concepts and principles of DAC6 in order to gain a better understanding of the field and interpret precisely the arrangements they may potentially face on a daily basis in their working environment.

More specifically:

corporate service providers and their officers;

accountants; tax and financial advisors;

banking consultants;

in-house legal team; agents;


The offered Professional Training Course contributes to Continuing Professional Development for 4 CPD Units


Venue: The course will be held online via zoom
Date & Time: 06th of March, 2024, 09:00-13:00 with a 15’ break
Language: Greek language with the slides in English


The seminar’s cost and duration for participation is presented on the table below:

Duration 4 hours
Participation Cost €150.00 + 19% VAT




To register please complete our online registration form here:


PART A: Overview

  • Scope of the DAC6 Directive
  • Intermediaries
  • Relevant Taxpayer
  • Reportable Cross-border Arrangement


PART B: The Hallmarks and the Main Benefit Test (MBT)

  • Overview of the Generic hallmarks and Specific hallmarks
  • Main Benefit Test (MBT)


Hallmark A - Generic Hallmarks Linked to MBT

  • A.1 -The “Confidentiality” hallmark
  • A.2 -The “Success fee” hallmark
  • A.3 -The “Standardized documentation” hallmark
  • Practical Questions & Examples


Hallmark B - Specific Hallmarks Linked to MBT

  • B.1 -The “Loss making company acquisition” hallmark
  • B.2 -The “Converting income scheme” hallmark
  • B.3 -The “Circular transactions” hallmark
  • Practical Questions & Examples


Hallmark C - Specific Hallmarks Related to Cross-Border Transactions

  • C.1 – The “Deductible cross-border payments” hallmark
  • C.2 -The “Double depreciation” hallmarks
  • C.3 -The “Double relief” hallmarks
  • C.4 -The “transfer of assets” hallmark
  • Practical Questions & Examples


Hallmark D - Specific Hallmarks concerning automatic exchange of information and beneficial ownership

  • D.1 - The “No CRS Reporting” hallmark
  • D.2 - The “Non-transparent Beneficial Ownership chain” hallmark
  • Practical Questions & Examples


Hallmark E - Specific Hallmarks concerning Transfer Pricing

  • E.1 - The “Unilateral safe harbour” hallmark
  • E.2 - The “Hard-to-value Intangibles” hallmark
  • E.3 - The “Business restructuring” hallmark
  • Practical Questions & Examples


PART C: Information to be reported

PART D: Timing aspects

PART E: Penalties for non-compliance



Marios Palesis, Partner, Tax Department

Marios is a qualified Accountant and a Fellow member of Association of Certified Chartered Accountants (FCCA), as well, as a member of the Institute of Certified Public Accountants of Cyprus, member of Advanced Diploma in International Taxation (ADIT) and International Tax Affiliate of the Chartered Institute of Taxation (CIOT).

Marios has significant experience in Transfer Pricing and international tax planning. He is servicing clients in Cyprus, Malta, Eastern Europe and in other jurisdictions around the globe.

His focus is on financial transactions and digital business


Contact Mrs. Ivi Papaioannou at academy@kinanis.com (22 558836)