A.2. Structures of Aggressive Tax Planning and relevant indicators per structure 94
The ATP Study identifies seven model ATP Structures. For each of them, the study further identifies a series of indicators (critical tax rules and practices) per country involved in the Structure. This annex presents the seven model ATP structure and indicators that are potentially relevant for Member States 95 .
Structure 1: Offshore loan ATP structure
Structure 2: Hybrid loan ATP structure
Structure 3 - Hybrid entity ATP structure
Structure 4 - Interest-free loan ATP structure
Structure 5 - Patent box ATP structure
Structure 6 - Two-tiered IP ATP structure
Structure 7: ATP structure based on IP and cost-contribution agreements
