On 4 February 2020, the Tax Revenue published a manual, entitled “e-Brief No. 029/20”, relating to the “main benefit test. The manual has been updated to include a reference to the EU mandatory disclosure regime (DAC6), which comes into force on 1 July 2020 and includes a “main benefit test”. The new regime includes a “lookback” reporting requirement, which will apply to reportable cross-border arrangements, the first step of which was implemented between 25 June 2018 and 30 June 2020.
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Transfer Pricing Brief: February 2020
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