Ireland Issues Guidance On Mandatory Disclosure Rules

; posted on
June 19th, 2018

The Irish Revenue issued a new Tax & Duty Manual related to the Directive regarding mandatory exchange of information in relation to reportable cross-border arrangements (DAC6). The manual provides a general overview of the scope of DAC6 and emphasizes that the Directive comes into force on June 25, 2018.

Scope of The Disclosure Requirement

DAC6 imposes mandatory reporting obligations on EU-based tax advisors, accountants, lawyers, banks, financial advisors and other intermediaries, who design, market, organise, make available for implementation or manage the implementation of potentially aggressive cross-border tax-planning schemes. It also covers persons who provide aid, assistance or advice in relation to potentially aggressive cross-border tax-planning schemes, where they can be reasonably expected to know that they have performed that function. The potentially aggressive cross-border arrangements are those which have certain characteristics indicating that the main purpose or one of the main purposes of the arrangement is to obtain a tax advantage.

Timing of Report

Under DAC 6, for the first reportable transactions are those where the first implementation step occurs between June 25, 2018 and July 1 2020. This information should be reported by August 31, 2020. With effect from July 1, 2020, a reportable arrangement must be reported by an intermediary within 30 days beginning on the day after the arrangement: (i) was made available for implementation, or (ii) was made ready for implementation, or (iii) when the first step in the implementation was undertaken, whichever occurs first.

Sources: Irish Tax and Custom

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