Tax consultancy

Mandatory Disclosure Rules (MDR) are one of the most demanding and risk-prone areas of tax law. Introduced to combat tax avoidance, these regulations require promoters, beneficiaries, and supporters to notify tax authorities of implemented or planned arrangements that meet certain criteria. Many business transactions, such as restructurings, dividend payments, and cross-border transactions, may be considered reportable arrangements. From the moment information about a planned arrangement is received, it is crucial to immediately conduct an MDR test to avoid significant financial penalties and fiscal liability.

Unlike one-off advice, MDR services are based on continuous monitoring of client operations, including general and specific identifying characteristics. Our support includes identifying domestic and cross-border schemes, preparing scheme information (MDR-1) and scheme use notifications (MDR-3). Maintaining a record of decision-making processes and accurately documenting the reasons why a given arrangement was deemed (or not) a scheme is fundamental to the security of management and internal counsel.

We place particular emphasis on maintaining professional confidentiality and meeting deadlines. Many entities exceeding revenue or cost thresholds (over €8 million) are legally required to have and implement an internal MDR procedure. BTTP offers comprehensive support in developing and implementing such procedures, which define the flow of information within the company and assign responsibility for identifying tax schemes. We help train finance and legal teams to independently identify tax schemes in their daily operations.