IEIM710010 - Introduction to Mandatory Disclosure Rules (MDR)

These rules introduce new obligations on taxpayers and their advisers to report Common Reporting Standard (CRS) Avoidance Arrangements and Opaque Offshore Structures. HMRC will share the information received with other tax authorities implementing equivalent rules.

CRS avoidance arrangements and Opaque Offshore Structures are defined in the Overseas for Economic Cooperation and Development (OECD) Model Mandatory Rules for CRS Avoidance and Opaque Offshore Structures. (Model Rules)

The legislation implements these Model Rules.

The legislation can be found here: The International Tax Enforcement (Disclosable Arrangements) Regulations 2023 (legislation.gov.uk) (SI 2023/38)