The Tax and Duty Manual Manual on DAC6 has been updated in a number of respects. The updates are set out in Appendix V.
The Manual has been updated in a number of respects and, where those updates are material, they are set out in Appendix V.
The following updates have been made:
- On page 6 of the previous version of this guidance, the final paragraph, which referred to point (d) in the definition of a cross-border arrangement, has been deleted;
- 2.1: The guidance on the meaning of tax residence has been amended;
- 6: The final paragraph of the guidance on hallmark A.2 has been deleted;
- 8: The guidance on the hallmarks in category C has been replaced;
- 9 In the guidance on multiple reporting, a new paragraph has been inserted before the example;
- 10: The guidance on legal professional privilege has been amended to provide additional guidance where the legal professional privilege exemption from disclosure applies in relation to only part of the specified information; and
- 5: In the guidance on multiple reporting, a new paragraph has been inserted.
Ireland’s mandatory tax disclosure regime became operational on July 1, 2020. However, in light of the COVID-19 pandemic, Ireland exercised an option to defer the first disclosures of information to January 2021. The deferral period will end on December 31, 2020, and the ROS DAC6 filing portal is scheduled to open on January 1, 2021.
The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also regularly writes news stories about transfer pricing and international tax law. Alex is reachable at editor@transferpricingnews.com