DAC7/MRDP

Overview

Note

Ireland has agreements in place under the Model Reporting Rules for Digital Platform Operators (MRDP) with Canada, New Zealand and the United Kingdom. Platform Operators are required to report sellers resident in or renting property in these jurisdictions.

The Model Reporting Rules for Digital Platform Operators (MRDP) is the agreed standard for automatic exchange of information (AEOI) on digital platform operators. It was approved by the OECD in June 2020. Ireland is one of the jurisdictions that have signed up to the MRDP.

Council Directive 2011/16/EU (DAC) provides for the exchange of taxpayer information between the tax administrations of EU Member States. In 2021, the DAC was amended by Council Directive (EU) 2021/514 (DAC7).

The MRDP and DAC7 obliges digital platform operators to collect and automatically report information on certain sellers using their platforms to earn consideration.

The MRDP and DAC7 obligations apply in respect of platforms that allow sellers to be connected with customers for the provision of the following for consideration:

• The sale of goods.
• The rental of immovable property (for example, accommodation).
• The provision of personal services (time- or task-based work carried out either online, or physically offline, after having been facilitated via a platform).
• The rental of any mode of transport.

The above are referred to as a ‘Relevant Activity’.

Irish legislation on MDRP and DAC7

The MRDP and DAC7 were transposed into Irish law by section 891I and section 891J of the Taxes Consolidation Act 1997 respectively.

These are supported by Regulations:

• S.I. No. 705 of 2022
• and
• S.I. No. 666 of 2023.

When and how information is exchanged with other jurisdictions

Under the legislation set out above, platform operators must file a return by 31 January in respect of the previous calendar year. A platform operator must, by 31 January, provide a reportable seller with a copy of their information as included in the return.

Revenue will exchange reported information with the relevant jurisdictions, where appropriate, within one month, by the end of February. Data exchanged with other Member States is done so under DAC7, and with third countries under the MRDP.

The first reporting of information under DAC7 was in respect of the calendar year 2023. For the year 2024, Revenue will also exchange information with the following jurisdictions under the MDRP:

• Canada
• New Zealand
• The United Kingdom (UK).

Revenue has published a list of reportable jurisdictions for the MRDP and DAC7.

Next: Registration obligations for platform operators