The crusading spirit is alive and well at Mishcon, whose new international tax partner Filippo Noseda is highly vocal about the ‘excesses of transparency’ brought in by the CRS. ‘Privacy and data protection are not a luxury. They are an integral part of any democratic society,’ he says. ‘There is a deafening silence surrounding the legality of the CRS.’ Noseda recently debated with the OECD and presented to the Council of Europe and EU data protection authorities on potential transparency reform. ‘Now is the time to bring the discussion about transparency and privacy back from the brink,’ he says. ‘The need to eradicate tax evasion is beyond doubt.’ The ex-Withers man says complete transparency infringes upon taxpayers’ human right to privacy: ‘The inadequacy of the CRS is evidenced by the possibility of achieving the same objective of fighting tax evasion through alternative means that are more respectful of the right of compliant citizens to privacy.’ But the CRS battle is only a ‘hobby’ outside his main role at Mishcon, where he looks after a wide spectrum of international HNWs and advises on tax disputes, wealth structuring and the establishment and restructuring of trusts and foundations. A dual qualified English solicitor and Swiss lawyer (Rechtsanwalt), he has advised a number of governments on the introduction of private foundations’ laws, and successfully lobbied the Swiss government on the recognition of trusts in 2007.
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