PART 1Introductory

Citation and commencement1

These Regulations may be cited as the International Tax Enforcement (Disclosable Arrangements) Regulations 2023 and come into force on 28th March 2023.

Interpretation2

1

In these Regulations—

  • “the model rules” means the OECD (2018) Model Mandatory Disclosure Rules for CRS Avoidance Arrangements and Opaque Offshore Structures, OECD, Paris, approved by the OECD’s Committee of Fiscal Affairs on 8th March 20183;

  • “HMRC” means His Majesty’s Revenue and Customs;

  • “partner jurisdiction” means any jurisdiction listed in Schedule 1;

  • “TCEA 2007” means the Tribunals Court and Enforcement Act 20074.

2

Any expression defined in the model rules5 but not in these Regulations has the same meaning in these Regulations as in the model rules.

3

Schedule 2 contains a table listing places where expressions that are used in these Regulations are defined or otherwise explained in the model rules.

4

In applying the model rules for the purposes of these Regulations “TIN” means—

a

the unique taxpayer reference number allocated to a person by HMRC,

b

if they do not have one, the reference number, if any, allocated to that person by another tax authority, or

c

if no such reference number has been allocated, the national insurance number, if any, allocated within the meaning of regulation 9 of the Social Security (Crediting and Treatment of Contributions, and National Insurance Numbers) Regulations 20016.