DAC6
Information contained in a DAC6 return
Council Directive (EU) 2018/822 (DAC6) requires returns of information to be filed in respect of each reportable cross-border arrangement. This information should be returned to Revenue.
Information in relation to the identity of each person coming within the definition of intermediary and relevant taxpayer involved in the arrangement, including:
- name
- whether the person is an individual or an entity
- if the person is an individual, their date and place of birth
- country of residence for tax purposes
- Taxpayer Identification Number (TIN)
- country of issuance of TIN
- the person’s address, where their TIN and/or its country of issuance is not known
- and
- where appropriate, the persons that are associated enterprises to each relevant taxpayer.
Other information which should be reported to Revenue in a DAC6 return are as follows:
- details of each hallmark that makes the arrangement reportable
- an outline of the content of the cross-border arrangement
- the reference number assigned to the arrangement, if any
- details of the statutory provisions that form the basis of the arrangement
- the value of the arrangement
- the date on which the first step was taken or will be taken in implementing the arrangement
- the Member State of each relevant taxpayer and any other Member State(s) likely to be concerned by the arrangement
- and
- the identification of any other person in a Member State likely to be affected by the arrangement.
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