Any transaction,  scheme or arrangement that has been designed to circumvent or is marketed as or has the effect of circumventing reporting obligations or exploiting an absence thereof under the Common Reporting Standard (CRS).
Any transactions, schemes or arrangements that are defined as an Opaque offshore structure which includes a passive offshore vehicle. A passive offshore vehicle means a Legal Person or Legal Arrangement that does not carry on a substantive economic activity supported by adequate staff, equipment, assets and premises in the jurisdiction where it is established or is tax resident.