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	DAC 6 - Reporting obligations of Tax Intermediaries Reporting by Tax Intermediaries under the Mandatory Disclosure rules commences this month. The following is an overview of the upcoming deadlines and the sources of guidance available.

Upcoming deadlines

12 January 2021 - deadline for non-disclosing intermediaries to notify another intermediary / the taxpayer with respect to cross-border arrangements subject to reporting in the period from 25 June 2018 to 31 December 2020 (in all other cases, non-disclosing intermediaries must notify another intermediary / the taxpayer within 7 working days from the date the trigger point arises);

31 January 2021 - deadline for filing information where the trigger point for reporting took place between 1 July 2020 and 31 December 2020 (30-day period commenced on 1 January 2021);

28 February 2021- deadline for filing information in respect of reportable cross-border arrangements the first step of which was implemented between 25 June 2018 and 30 June 2020.

CfR Guidance - Interpreting the Mandatory Disclosure Rules

Earlier this week the Commissioner for Revenue published Guidelines on the Mandatory Automatic Exchange of Information in relation to Cross-Border Arrangements.

The guidelines are to be read in conjunction with the provisions of the Cooperation with Other Jurisdictions on Tax Matters Regulations (S.L. 123.127), which implement the provisions of DAC 6 (Council Directive 2018/822) into local legislation.

Click on the link below to view version 1.0 of the Guidelines.

Guidelines

DAC 6 Reporting Entity Registration

DAC6 Reporting Entities required to submit information in relation to reportable cross-border arrangements must be registered for this purpose.

Registration

DAC 6 XML Schema

The DAC6 XML Schema to be used for filing information in relation to reportable cross-border arrangements and the DAC6 XML Schema user guide are available on the CfR website. Click the link below for further details.

Further to a review of the User Guide, the MIT has requested some clarifications from the Office of the CfR and has documented the replies in the attached MIT Q&A Document.

DAC 6 XML Schema

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