The UK has published the International Tax Enforcement (Disclosable Arrangements) Regulations 2023, which enter into force on 28 March 2023. The new regulations provide for the introduction of new mandatory disclosure rules based on the OECD's Model Mandatory Disclosure Rules for CRS Avoidance Arrangements and Opaque Offshore Structures. The new regulations also revoke the International Tax Enforcement (Disclosable Arrangements) Regulations 2020, which transposed Council Directive (EU) 2018/822 (Directive) (DAC6), as well as subsequent amendment regulations. Under the new regulations, an intermediary is generally required to make a return of information if it either: (i) makes a CRS avoidance arrangement or...