The OECD has just published new model disclosure rules proposing that lawyers, accountants, financial advisors, banks and other service providers be obliged to inform tax authorities of any schemes they put in place for their clients resulting in reporting being avoided under the OECD/G20 Common Reporting Standard (CRS), or preventing the identification of the beneficial owners of entities or trusts. The proposed OECD disclosure rules provide an exemption for legal professional privilege.

These model disclosure rules will be submitted to the G7 presidency and are part of a wider strategy of the OECD to strengthen disclosure rules. Ireland has mandatory disclosure obligations for intermediaries in place since 2011; another instance of where early adoption of international best practice did nothing to quieten the whines of complaint from international competitors about the probity of our tax system.