What is an intermediary?
Someone who designs, markets, organises, makes available for implementation, or manages the implementation of a reportable cross-border arrangement.
It includes someone who provides aid, assistance or advice – to the extent they can reasonably be expected to know that is what they have done
An employee is not an intermediary but partners in partnerships can be (although partnerships can report on behalf of their partners)
Sole trader individuals may have to make intermediary reports
There are two types of intermediary:
- Promoters – those who design, promote and implement
- Service providers – those who provide assistance or advice
Service providers (but not promoters) may have a “knowledge defence”. If this applies, they do not need to report.