Ireland’s Revenue Commissioners have revised Tax and Duty Manual Part 33-03-03 to reflect DAC8 changes, detailing the requirement for a detailed description of reportable cross-border arrangements and any information that could help assess potential tax risks.
Ireland’s Revenue Commissioners published eBrief No. 067/26 on 30 March 2026, updating guidance on the application and operation of DAC6.
DAC6 mandates reporting of cross-border tax arrangements showing specific “hallmarks” of potential tax avoidance, like confidentiality clauses or aggressive planning. Intermediaries or taxpayers disclose details to tax authorities for automatic exchange across EU states, enhancing transparency and curbing BEPS risks.
The Tax and Duty Manual, Part 33-03-03, offers detailed guidance on DAC6. The manual has been revised to reflect changes to section 817RA(3)(c) of the Taxes Consolidation Act 1997, following the transposition of Council Directive (EU) 2023/2226 (DAC8).
Chapter 3.1, which lists the information required for each reportable cross-border arrangement, has been amended. Paragraph (c) now removes the reference to an abstract summary of the business environment and instead requires a description of the relevant arrangements, along with any additional information that could help a competent authority assess potential tax risks.
