Generally, the MDR reporting requirement applies where a hallmark is present in one of the three categories of hallmarks, yet the hallmarks in one category only must additionally involve the presence of a tax advantage. Reportable may often be schemes applied for the purpose of ongoing business operations, including those generating low value and/or applied in line with statutory rules. For example, reportable may be an operating lease, a transfer of dividends abroad, payment of royalties to a foreign jurisdiction, restructuring operations such as mergers, demergers, contributions to a company involving an allocation to supplementary capital (agio), use of safe harbours for loans, replacing the staff’s employment contracts with sole trader schemes, claiming 50% tax deductible costs for copyright work, intra-Community acquisitions of excisable goods outside the duty suspension procedure, a transfer of a client database and/or other intangible assets, implementation of a Polish investment zone, triangular transactions arrangements, change of VAT reporting periods.