In issue 3 of 2018 of Irish Tax Review Directive 2011/16/EU on information exchange, known colloquially as “DAC 6”, was compared to the familiar (for some) Irish regime for mandatory reporting of transactions with certain (tax-avoidance) characteristics. Since then, DAC 6 has been transposed into a new Part 33, Chapter 3A, TCA 1997, and Revenue guidance thereon has been released. Intermediaries and taxpayers should now be tracking arrangements for potential reportability. In this article the available guidance is considered, as practitioners “look forward” to filings in 2021.
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