Model Mandatory Disclosure Rules for CRS Avoidance Arrangements and Opaque Offshore Structures
by Luigi Benincasa
The “Model Mandatory Disclosure Rules for CRS Avoidance Arrangements and Opaque Offshore Structures” complement the CRS and improve the quality of the exchange of information in tax matters. With the enhancement of the EU Directive on Administrative Cooperation ("DAC 6") requiring new reporting obligation as of 2020 for cross-border tax planning arrangements, the European Union has basically adopted them. Accordingly, there is no doubt that Switzerland will sooner or later adopt its principles. Therefore, for every Swiss financial intermediary it is time to start with a brainstorm in order to understand how it will be impacted.