The International Tax Enforcement (Disclosable Arrangements) Regulations 2023
These Regulations make provisions implementing the OECD (2018), Model Mandatory Disclosure Rules for CRS Avoidance Arrangements and Opaque Offshore Structures, OECD, Paris. They impose obligations on persons, known as intermediaries or reportable taxpayers, to report information to HM Revenue and Customs (“HMRC”) about certain types of arrangements, known as CRS avoidance arrangements and opaque offshore structures.