International Exchange Framework for Mandatory Disclosure Rules on CRS Avoidance Arrangements and Opaque Offshore Structures



Published: 27 June 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 designed the international legal and operational framework for MDR exchanges.

The legal part of the MDR exchanges will be ensured through a multilateral Competent Authority Agreement (MCAA). 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 has developed 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.


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