BackgroundGibraltar’s Mandatory Disclosure Regime (MDR) imposes a requirement to disclose to the Commissioner of Income Tax any cross-border arrangement or transaction that falls within any of a number of specific “hallmarks.” If there is an “intermediary” involved, the onus to report is on the intermediary. In the absence of an intermediary, the reporting requirement falls to the taxpayer.The Income Tax (Amendment) Regulations 2020 made the necessary amendments to Gibraltar’s Income Tax Act 2010 in order to introduce the legislation. MDR was applied in Gibraltar in order to implement EU Directive 2018/822, otherwise known as “DAC6,” on the mandatory automatic exchange of information...