Since the Automatic Exchange of Information (AEol, CRS) was introduced globally, the OECD and the EU have been working towards closing any loopholes.
Already in March 2018, the OECD accepted the “Mandatory Disclosure Rules for CRS Avoidance Arrangements and Opaque Offshore Structures” (OECD MDR).
A few months later, the EU enacted a directive regarding the introduction of mandatory disclosure rules concerning reportable cross-border arrangements (EU MDR).
In parallel, the OECD launched a further initiative called “Preventing abuse of residence by investment schemes to circumvent the CRS’,’ aimed at fictitious tax residences based on investments.
Besides these initiatives, the Ultimate Beneficial Owner Registers (UBO Registers) and (group) requests for administrative assistance lead to further tax transparency.
Read this useful update – https://assets.kpmg/content/dam/kpmg/ch/pdf/tax-transparency.pdf