27/06/2019 – In order to support the automatic exchange of information collected under the OECD's Model Mandatory Disclosure Rules (MDRs) on Common Reporting Standard (CRS) Avoidance Arrangements and Opaque Offshore Structures, the OECD has today released the international administrative and operational framework for the exchange of information collected under the MDRs.
The MDR exchanges will be based on a multilateral Competent Authority Agreement (MCAA), the draft of which is included in today's publication. The MCAA will enable a jurisdiction that received information about a CRS Avoidance Arrangement or Opaque Offshore Structure under the MDRs to exchange such information with all jurisdictions of tax residence of the concerned taxpayers. This will allow tax authorities of such jurisdictions to use such information to carry out compliance activities with respect to both the taxpayers and the intermediaries involved in the arrangements disclosed under the MDRs.
In order to support the operational and technical side of the MDR exchanges, the OECD is also releasing the MDR XML Schema and User Guide to support MDR exchanges, which will facilitate the structured collection and exchange of information on CRS Avoidance Arrangements and Opaque Offshore Structures.
Separately, the OECD is releasing updated XML schemas and guidance to support the exchange of tax information under the Common Reporting Standard (CRS), on Country-by-Country (CbC) Reporting and in relation to tax rulings (ETR). The updates to the several user guides and XML schemas reflect the experiences gained from first exchanges, aim at increasing the user-friendliness and contain the latest technical developments.
The CRS and CbC-related schemas will become effective for all exchanges on or after 1 January 2021, whereas the ETR-related schemas will take effect as from 1 April 2020.
The different updated XML schemas and user guides may be accessed here:
Queries should be directed to Achim Pross, Head of the International Co-operation and Tax Administration Division at the OECD Centre for Tax Policy and Administration (+33 1 45 24 98 92) or the CTP Communications team.