In short, the proposal is too broad in many respects, ignoring the principle of technology neutrality in regulation. My comments can be found here.
You can read the OECD’s public consultation draft here: https://www.oecd.org/ctp/exchange-of-tax-information/oecd-seeks-input-on-new-tax-transparency-framework-for-crypto-assets-and-amendments-to-the-common-reporting-standard.htm.
Brief commentary on the crypto-asset reporting framework (CARF) proposed by the OECD
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