Loyens & Loeff: New EU Mandatory Disclosure Rules for intermediaries applying to cross-border tax advice and circumvention of reporting obligations

On 13 March 2018, the Council of the European Union reached political agreement on a Council Directive (“Directive”) introducing mandatory disclosure rules for intermediaries such as lawyers, accountants and tax advisers. Intermediaries must report potentially aggressive tax planning arrangements with a cross-border dimension as well as arrangements designed to circumvent reporting requirements like CRS and UBO reporting. EU Member States’ tax authorities will exchange the information automatically within the EU through a centralized database.


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