CONSULT.Outcome publishedConsultation · gov.uk
Draft regulations: Mandatory Disclosure Rules
We welcome views on the design of draft regulations requiring disclosure of certain arrangements to HMRC.
Last fetched 03 May 2026 · gov.uk
Detail
At Budget 2021, the government announcement that it would implement the Organisation for Economic Cooperation and Development’s (OECD’s) ‘Model Mandatory Disclosure Rules for Common Reporting Standard (CRS) Avoidance Arrangements and Opaque Offshore Structures’.
The model rules require taxpayers and intermediaries to disclose information on these types of arrangements and structures to HMRC. These regulations will replace similar EU rules introduced previously.
You can read the consultation document and the draft regulations on this page.
Documents
Mandatory Disclosure RulesMandatory Disclosure Rulesapplication/pdfMandatory Disclosure Rules (open document format)application/vnd.oasis.opendocument.text(Draft) The International Tax Enforcement (Disclosable Arrangements) Regulations 2022application/pdfMandatory Disclosure Rules: summary of responses