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Mandatory Disclosure Rules

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Guernsey has committed to introduce Mandatory Disclosure Rules for Common Reporting Standard Avoidance Arrangements and Opaque Offshore Structures ("MDR") by 31 December 2019.

Similar commitments were made by Jersey and the Isle of Man.

These rules would require promoters of avoidance arrangements and service providers to disclose information on the arrangement or structure to the Revenue Service. Such information would include the identity of any user or beneficial owner and would then be exchanged with the tax authorities, of the jurisdiction in which the users and/or beneficial owners are resident, where there is a relevant information exchange agreement.

Whilst not currently one of the BEPS Minimum Standards, the rules effectively set out a "best practice" measure to assist in countering CRS avoidance, therefore, their introduction is considered to be an inevitable part of the CRS compliance strategy for the Revenue Service.

For more information please see the briefing note available to download on this page.

If you have any comments on the briefing note, please email EOI@gov.gg with the subject line "MDR".

Downloads

MDR - Briefing Note

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