Executive summaryIn October 2019, the French Tax Code (FTC) was supplemented with Articles 1649 AD to 1649 AH, implementing the European Union (EU) Directive 2018/822 of 25 May 2018 on the mandatory disclosure and automatic exchange of cross-border tax arrangements (referred to as DAC6 or the Directive).The French Tax Authorities (FTA) subsequently published official detailed draft guidance regarding the definitions of the terms and the reporting process under the French Mandatory Disclosure Rules (MDR) on 9 March 2020. The FTA published additional official detailed draft guidance dedicated to hallmarks on 29 April 2020.On 25 November 2020, the FTA published the final guidance (referred to herein as the...