Revenue Guidance on Mandatory Disclosure for Intermediaries – DAC6
The Revenue Commissioners issued guidance today on the implementation of Council Directive (EU) 2018/822 of 25 May 2018 amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation in relation to reportable cross-border arrangements, commonly referred to as “DAC6”. The Revenue Commissioners confirmed that the obligations arising from DAC6 will take effect from 25 June 2018.
DAC6 introduces an obligation on persons to disclose potentially aggressive tax planning arrangements and on tax administrations to subsequently exchange this information. These mandatory reporting requirements are applicable to 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.
The Revenue Commissioners guidance on the implementation of DAC6 can be accessed here.
To the extent that you are impacted by the content of this briefing, please feel free to contact Eleanor MacDonagh, Alan Heuston, Michael Ryan or another member of our Tax Department.
This document has been prepared by McCann FitzGerald LLP for general guidance only and should not be regarded as a substitute for professional advice. Such advice should always be taken before acting on any of the matters discussed.
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