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.