Revenue eBrief No. 134/20

03 July 2020

EU mandatory disclosure regime (DAC6)

Council Directive (EU) 2018/822 (the “DAC6”) came into operation on 1 July.  The DAC6 introduces a new EU mandatory disclosure regime for certain cross-border transactions that could potentially be used for aggressive tax planning.  These are referred to as reportable cross-border arrangements.  Tax and Duty Manual Part 33-03-03 provides general guidance on how the regime will operate in Ireland. 

In light of the restrictions imposed on businesses during the Covid-19 pandemic, Ireland is exercising an option given to Member States in Council Directive (EU) 2020/876 to postpone by six months the filing dates for the first returns of information in relation to reportable cross-border arrangements.  This means that reporting to Revenue will not commence until January 2021 at the earliest.  Details of the revised filing deadlines are included in the manual.