OECD : Releases model rules requiring intermediaries to disclose CRS Avoidance arrangement, opaque offshore structures

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