MDR (mandated disclosure rules) went into effect in numerous EU nations in 2020. The laws apply to any corporation conducting business in the EU (regardless of its location) as well as any tax-aggressive arrangement or transaction that crosses EU borders.

The intermediary that establishes or implements the tax-aggressive cross-border arrangement in question should have primary MDR reporting requirements, although compliance obligations can be passed to their customer (the taxpayer). In turn, states outside the EU will almost certainly adopt MDR-style procedures.

EU member states can also choose to localise their implementations. This could lead to a maze of complexity and significant MDR compliance costs linked to: