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The International Tax Enforcement (Disclosable Arrangements) Regulations 2023
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- UK Statutory Instruments
- 2023 No. 38
- PART 2
- Regulation 12
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12.—(1) A person (“P”) is not to be treated as an intermediary in relation to a CRS avoidance arrangement or an opaque offshore structure where—
(a)P is an employee of an employer (“E”), and
(b)E is an intermediary or relevant taxpayer in relation to the CRS avoidance arrangement or opaque offshore structure.
(2) In this regulation, “employee” and “employer” have the meanings given by section 4 of the Income Tax Earnings and Pensions Act 2003(1) (as read with section 5(2) of that Act).
(3) For the purposes of this regulation, where E is connected to another person (“F”), P is to be treated as an employee of F as well as being an employee of E.
(4) In this regulation, E is connected to F where E is closely bound to F by financial, economic or organisational links.
(1)
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