OECD releases new model
disclosure rule requiring lawyers, accountants, financial advisors,
banks, etc. to inform tax authorities of schemes they put in place for clients
to avoid reporting under Common Reporting Standard (CRS) or prevent
identification of beneficial owners of entities or trusts; Model rules
require an Intermediary or user of a CRS Avoidance Arrangement or Opaque
Offshore Structure to disclose certain information to its tax
administration; Where such information relates to users that are resident
in another jurisdiction it would be exchanged with the tax administration of
that jurisdiction in accordance with the terms of the applicable international
legal instrument; Model Rule defines hallmark for CRS Avoidance Scheme and
for Opaque Offshore Structures which specifically targets Passive
Offshore Vehicles that are held through an Opaque Structure; Further, Model
Rules provide for definition of intermediaries, timing of disclosure
requirements, information to be disclosed and penalties and other mechanisms to
deal with non-compliance
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