In order for a cross-border arrangement to be reportable, it must meet one or more characteristics that are divided into five categories and include properties or characteristics that are most often found in aggressive tax planning arrangements. The categories of characteristics of cross-border arrangements are:
1. general features related to the main benefit test,
2. special features related to the examination of the basic benefit,
3. special features related to cross-border transactions,
4. special features related to the automatic exchange of information and beneficial ownership,
5. special features related to transfer prices.