OECD – COMPILATION OF COMMENTS PUBLIC COMMENTS ON THE DISCUSSION DRAFT ON MANDATORY DISCLOSURE RULES FOR ADDRESSING CRS AVOIDANCE ARRANGEMENTS AND OFFSHORE STRUCTURES. On 11 December 2017, interested parties were invited to provide comments on a discussion draft on model mandatory disclosure rules. The model rules are intended to target promoters and service providers with a material involvement in the design, marketing or implementation of CRS avoidance arrangements or offshore structures. The proposed rules would require such intermediaries to disclose information on the scheme to their national tax authority. The rules contemplate that information on those schemes (including the identity of any user or beneficial owner) would then be made available to other tax authorities in accordance with the requirements of the applicable information exchange agreement. 18 January 2018.