The Commissioner for Revenue will be deferring – by six months - the first reporting deadlines of the Mandatory Disclosure Rules (DAC6), an EU directive which imposes the mandatory exchange of information on intermediaries and taxpayers in an effort to regulate cross-border tax arrangements.

The deferral is in line with a coming into force of an agreement reached within the European Council on the 24th June, addressing the need to extend some time limits for the filing and exchange of taxation information. This aims to give taxpayers and intermediaries some additional lee-way in light of the challenges they may have been dealing with in the wake of COVID-19.

A legal notice announcing the deferral is set to be issued over the coming weeks, and the Commissioner for Revenue has said it intends to publish guidelines over the coming the coming months to help businesses prepare the paperwork in line with reporting obligations.

Auditing firm KPMG, in a statement, said that the new deadlines are as follows: 

• February 28, 2021 (previously August 31, 2020) for arrangements where the first step was implemented between June 25, 2018 and 1 July, 2020 (so-called “historical arrangements”); 
• January 1, 2021 as the start date for the 30 days reporting deadline. This will also apply with respect to cross-border arrangements for which the reporting trigger occurs between July 1, 2020 and December 31, 2020; 
• January 30, 2021 for a reportable cross-border arrangement that is made available for implementation or is ready for implementation, or where the first step in its implementation has been made during the deferral period; 
• April 30, 2021 for the first periodic report on marketable arrangements.

Penalties for late reports are capped at EUR 20,000.

For more information, visit KPMG’s EU Tax Centre.