The year 2016 will be remembered as a key milestone in international tax transparency. Following a number of tax transparency and anti-avoidance measures resulting from the BEPS recommendations, LuxLeaks, Panama Papers and the like, 2017 looks to be equally eventful.

A new proposal is in the works to require intermediaries to file information concerning cross-border reportable arrangements at EU level, a criminal offence for failure to prevent the criminal facilitation of tax evasion in the UK has been recently introduced, and multiple tax transparency measures across Asia are being taken. These changes will impact not only taxpayers engaged in “aggressive” tax planning, but will raise practical issues for “ordinary” planning and compliance.