For Intermediaries (promoters and service providers).  They promote or assist in an arrangement that is designed or marketed as circumventing reporting obligations for the CRS and promoting or assisting with setting up Opaque offshore structures.
 and they meet one of the following conditions. 
 They are resident in the UK,
They have their place of management in the UK,
They have a branch or office in the UK through which it carries out the activities that makes it an intermediary in respect to the arrangement or structure,
They are  incorporated in the UK.

For a taxpayer they are  any actual or potential user of that Arrangement and, in respect of an Opaque Offshore Structure, a natural person whose identity as a Beneficial Owner cannot be accurately determined due to the Opaque Offshore Structure.
They are UK resident. 
The arrangement including the details of the taxpayer have not been reported by an intermediary