On 27 January 2021, the Irish Revenue published an eBrief No. 014/21 regarding EU mandatory disclosure of reportable cross-border arrangements. On the similar day, the Revenue also published a Tax and Duty Manual, providing guidance where certain specified information in a disclosure is subject to Legal Professional Privilege (LPP).

In such cases, a Form DAC 6 (LPP) should be filed using MyEnquiries, setting out the identity of the relevant taxpayer and other intermediaries involved in the reportable cross-border arrangement. A copy of the Form DAC6 (LLP) is available on the Revenue website.