UK Mandatory Disclosure Rules (MDR): CRS avoidance and opaque offshore structures—hallmarks, intermediaries and reportable taxpayers, reporting duties, time limits, exemptions, penalties, and transition from DAC 6
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OECD’s Model Mandatory Disclosure Rules
The Organisation for Economic Co-operation and Development (OECD) released its model Mandatory Disclosure Rules (MDR) covering Common Reporting Standard (CRS) Avoidance Arrangements and Offshore Structures in March 2018, with the objective of achieving country-by-country alignment in applying disclosure and transparency to combat aggressive tax planning worldwide. The model MDR are described as ‘the model rules’ in The International Tax Enforcement (Disclosable Arrangements) Regulations 2023, SI 2023/38 (the MDR regulations), which bring the MDR into effect in the UK. In this Practice Note, references to the model rules and the model MDR are to the OECD’s model MDR. References to the MDR and MDR regulations denote the rules in SI 2023/38 that implement the model MDR domestically. Under the model rules, taxpayers and their advisers must provide tax authorities with information on specified arrangements and structures that could enable tax evasion. Where jurisdictions have implemented the rules, their tax authorities exchange this data with the authority in the jurisdiction of the taxpayer’s residence. Implementation of the MDR in the UK Common Reporting Standard for automatic exchange of financial account information (CRS) Endorsed in July 2014, the CRS for automatic exchange of the CRS for automatic exchange of the...
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Web page updated on 22/05/2026
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