IEIM721010 - Definition of Intermediary
An intermediary is not defined in the regulations, so Regulation 2(2) applies so that the definition is taken from the Model Rules. The definition of intermediary in the Model Rules is at Rule 1.3.This reads:
바카라 사이트渋ntermediary바카라 사이트� means
(a) any person responsible for the design or marketing of a CRS Arrangement or Opaque Offshore Structure. (바카라 사이트淧romoter바카라 사이트�) and
(b) any person that provides Relevant Services in respect of a CRS Avoidance Arrangement or Opaque Offshore Structure in circumstances where the person providing such services could reasonably be expected to know that the Arrangement or Structure is a CRS Avoidance Arrangement or an Opaque Offshore Structure (바카라 사이트淪ervice Provider바카라 사이트�) The standard of 바카라 사이트渞easonably expected to know바카라 사이트� must be determined by reference to the Service Provider바카라 사이트檚 actual knowledge based on readily available information and the degree of expertise and understanding required to provide the Relevant Services.
The definition envisages two distinct types of intermediaries: those who design and market a CRS Arrangement or Opaque Offshore Structure (referred to as 바카라 사이트榩romoters바카라 사이트�), and those who provide assistance or advice with respect to the design, marketing, implementing or organisation of a CRS Arrangement or Opaque Offshore Structure (referred to as 바카라 사이트榮ervice providers바카라 사이트�). This is subject to an exclusion in certain circumstances for persons who are employees. For more information on this see IEIM721080.