Due to coronavirus outbreak, the European Commission has recently agreed to delay the entry into force of certain European Union (EU) taxation measures. Among these is the delay of Council Directive 2018/822, commonly known as the Directive on Administrative Cooperation 6 (DAC6). The rules under DAC 6 are set to become applicable on July 1, 2020, with mandatory reporting requirements initially due in August 2020. However, the EC recently agreed to a six-month delay of the initial reporting deadlines as a result of COVID-19.
On 26 June 2020, the Irish Revenue published an eBrief No. 127/20 regarding the delay of DAC6 filing deadlines. Previously, the DAC6 reporting timelines was scheduled to enter into force on 1 July 2020. According to the e-brief, the Revenue extended the DAC6 reporting deadlines by six months. The 30-day time period for the reporting of information related to new reportable cross-border arrangements will now commence on 1 January 2021. For any reportable cross-border arrangements made between 1 July 2020 and 31 December 2020, the 30-day reporting period also commences on 1 January 2021. Again, the new reporting due date is 28 February 2021 for reportable cross-border arrangements, the first step of which was implemented between 25 June 2018 and 30 June 2020. In addition, The new reporting deadline for periodic reporting on marketable arrangements is 30 April 2021. Finally, the DAC6 filing portal will open on 1 January 2021.
