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Proposed changes to Ireland’s implementation of DAC6 were announced in the Finance Bill 2020. Some of the relevant changes include:

Additional DAC6 exemptions: DAC6 will no longer apply to fees, such as for certificates and other documents issued by public authorities; and dues of a contractual nature, such as consideration for public utilities.

New intermediary exemptions: An intermediary will be exempt from making a return to the Revenue Commissioners if they receive confirmation that such other intermediary has reported, a copy of the specified information provided to the competent authority or an Arrangement Reference Number. 

Notification requirements where legal professional privilege applies: The intermediary concerned shall, without delay, notify the relevant taxpayer of the obligations imposed on that relevant taxpayer.

Change to duties of the relevant taxpayer”: An intermediary will be exempt from making a return to the Revenue Commissioners if they receive confirmation that another intermediary has reported (for example via an Arrangement Reference Number).

Hallmark A3: There is a new list of specified arrangements that breach hallmark A3.

VinciWorks is working closely with tax authorities across the EU including Ireland and a complete XML report can be produced via its DAC6 reporting software.