associated enterprisemeans a person who is related to another person in at least one of the following ways: If more than one person participates, as referred to in points (a) to (d), in the management, control, capital or profits of the same person, all persons concerned shall be regarded as associated enterprises.
bespoke arrangementmeans any cross-border arrangement that is not a marketable arrangement.’;
cross-border arrangementmeans an arrangement concerning either more than one Member State or a Member State and a third country where at least one of the following conditions is met: For the purposes of points 18 to 25 of this Article, Article 8ab and Annex IV, an arrangement shall also include a series of arrangements.
hallmarkmeans a characteristic or feature of a cross-border arrangement that presents an indication of a potential risk of tax avoidance, as listed in Annex IV.
intermediarymeans any person that designs, markets, organises or makes available for implementation or manages the implementation of a reportable cross-border arrangement.
marketable arrangementmeans a cross-border arrangement that is designed, marketed, ready for implementation or made available for implementation without a need to be substantially customised.
relevant taxpayermeans any person to whom a reportable cross-border arrangement is made available for implementation, or who is ready to implement a reportable cross-border arrangement or has implemented the first step of such an arrangement.
reportable cross-border arrangementmeans any cross-border arrangement that contains at least one of the hallmarks set out in Annex IV.