Following the work carried out by the G20 / OECD under the Base Erosion and Profit Shifting (BEPS) project, namely Action 12 on mandatory reporting rules, and the implementation of the Common Reporting Standard ("CRS"), the OECD published a Mandatory Disclosure Rules Model for Schemes that Avoid CRS and Opaque Offshore Structures. Within a broader framework, at recent ECOFIN meeting, the European Union approved the extension of administrative cooperation and exchange of information for tax purposes through the new directive against abusive tax planning, mainly through the disclosure of tax schemes by intermediaries ("DAC 6").