DAC6 Mandatory Disclosure in Ireland: Revenue Intermediaries Guide

DAC6 is the EU rule that requires certain cross-border tax arrangements to be reported to tax authorities. In Ireland the people who report are mainly intermediaries, which means the advisers who design, market, organise or manage a reportable arrangement, and in some cases the taxpayer. This guide sets out what Revenue's own pages and Tax and Duty Manual say about who reports, what is reportable and how a return is filed. It does not cover penalty amounts; for those, read the manual and the legislation directly.

This is general information, not tax or legal advice. Revenue's DAC6 web pages show a last-updated date of 2 September 2026, and the Tax and Duty Manual Part 33-03-03 shows "Document last updated March 2026". The rules and guidance can change, so check the current pages before you act on a specific arrangement.

What DAC6 is

Revenue's DAC6 overview page explains that Council Directive 2011/16/EU (the DAC) provides for the exchange of taxpayer information between EU tax administrations, and that DAC6 (Council Directive (EU) 2018/822) amended it in 2018 to introduce a mandatory disclosure regime for certain cross-border arrangements. According to Revenue, the regime came into operation on 1 July 2020 and is intended to help Member States respond to harmful tax practices by closing loopholes, undertaking risk assessments and carrying out compliance interventions.

The process has two steps. Intermediaries, and in some cases taxpayers, give information on reportable cross-border arrangements to their tax authority, and that authority then exchanges the information with other Member States. In Ireland the rules are in Chapter 3A of Part 33 of the Taxes Consolidation Act 1997, introduced by section 67 of the Finance Act 2019, together with the European Union (Administrative Cooperation in the Field of Taxation) (Amendment) Regulations 2019, as Revenue's overview page states.

What makes an arrangement reportable

Revenue's page "What is reportable under the EU Mandatory Disclosure Regime" describes reportable cross-border arrangements as arrangements involving an EU Member State and another jurisdiction that carry at least one "hallmark". The page groups the hallmarks into five categories:

1. arrangements involving confidentiality, standardised documents, or fees contingent on a tax advantage;
2. arrangements involving acquiring losses, converting income, or round-tripping of funds;
3. arrangements involving cross-border payments, double deduction, double relief and consideration mismatch;
4. arrangements concerning automatic exchange of information and beneficial ownership; and
5. arrangements concerning transfer pricing.

The Tax and Duty Manual goes into more detail. It defines an arrangement broadly, including verbal agreements and multi-step arrangements. A cross-border arrangement meets at least one of five conditions, such as participants in different tax jurisdictions, dual tax residence (for individuals, see our guide to tax residency in Ireland), involvement of a permanent establishment, or a possible effect on automatic exchange of information or beneficial ownership identification. Merely advising a participant does not make someone a participant.

The manual also explains the "main benefit test". A tax advantage must be the main benefit, or one of the main benefits, that a person may reasonably expect from the arrangement, judged objectively. According to the manual this test applies to the category A and B hallmarks and some category C hallmarks, while other hallmarks are reportable whatever the tax benefit. The manual says VAT, customs duties, excise duties and compulsory social security contributions are excluded from the taxes covered.

The manual labels its hallmark categories A to E. In summary, A covers generic hallmarks such as confidentiality conditions, success-linked fees and off-the-shelf structures; B covers specific hallmarks such as using losses or converting income; C covers cross-border payments and mismatches; D covers exchange of information and beneficial ownership; and E covers transfer pricing. Because several sub-conditions depend on the main benefit test, anyone assessing a real arrangement should read the manual chapter and not rely on a summary.

Who is an intermediary

Revenue's web page says an intermediary is any person who designs, markets, organises or manages the implementation of a reportable cross-border arrangement. The manual widens this. It describes two categories: first, those who design, market, organise, make available or manage implementation (it names tax lawyers, advisers and in-house group experts); and second, anyone who knows or could reasonably be expected to know that they undertook to provide aid, assistance or advice on such an arrangement, directly or through others. The manual says this second category covers a wider group, such as accountants, auditors, wealth managers and insurers.

The manual also sets a connection requirement. A person must be tax resident in a Member State, have a permanent establishment in a Member State through which services are provided, be incorporated or governed by the law of a Member State, or be registered with a relevant professional body in a Member State. "Person" is broad, covering individuals, companies and partnerships, and the manual says employees act for their employer and partners for the partnership.

For accountants, this means the question is not only whether you are a tax adviser by title. It is whether, on the facts, you fall within the manual's descriptions. Our suggestion: keep engagement notes that record what your role was in any cross-border structuring work, since the manual refers to information within your "knowledge, possession or control" and to taking reasonable steps to obtain what you do not have.

When the taxpayer reports instead

Revenue's web page defines a relevant taxpayer as any person to whom a reportable arrangement is made available for implementation, who is ready to implement it, or who has implemented its first step. The intermediary normally files. The taxpayer must file where there is no intermediary, or where the taxpayer has not waived their legal privilege.

The manual deals with nexus to Ireland in priority order: tax residence, then a permanent establishment benefitting from the arrangement, then receiving income or profits without residence or a permanent establishment, then carrying on an activity without either. If another Member State ranks first, the taxpayer files there and is exempt from filing in Ireland, provided that filing contains all the required information; the taxpayer must keep a copy and written confirmation of the Arrangement ID. For individuals, Irish tax residence is therefore a likely starting point, and the tax residency guide linked earlier explains how residence is determined.

Legal professional privilege

The manual says an intermediary is exempt from filing information if a claim to legal professional privilege over it could be maintained in legal proceedings, and if only part is privileged the exemption covers only that part. It states that privilege generally covers confidential legal advice from a lawyer to a client and does not extend to ordinary transaction documents or the identity of the parties, except where litigation is in actual contemplation. Privilege belongs to the client, who may waive it, and lawyers marketing an arrangement cannot claim it.

Where an exemption applies, the intermediary must notify the relevant taxpayer of the filing obligation "without delay". For partial privilege, the intermediary files the non-privileged part, shares the Arrangement ID and notifies the taxpayer, who must then file all specified information within 14 days of receiving the ID. Revenue's filing page adds that you cannot file on ROS for information subject to privilege; instead, Form DAC6 (LPP) is filed through MyEnquiries, setting out the identity of the relevant taxpayer.

The manual's description of privilege is the one that matters for DAC6, though accountants may also want to consider how the reporting duty sits alongside the ethical duties in our guide to the IESBA Code of Ethics for professional accountants in Ireland. That is our suggestion for further reading, not a statement of what the DAC6 rules require.

Timing and filing

Revenue's web page says a DAC6 return must be filed within 30 days of the earliest of three events: the day after the arrangement is made available for implementation, the day after it is made ready for implementation, or when the first implementation step is taken in relation to the relevant taxpayer. The manual repeats the 30-day period for arrangements whose first step was on or after 1 July 2020. It also describes a look-back period for earlier arrangements and says there is no disclosure obligation for arrangements whose first step was before 25 June 2018.

Revenue's "How to file a DAC6 return" page says filing is through the Revenue Online Service (ROS). If you do not have ROS access you first register as a reporting entity using the reporting entity registration form, and an agent can register a client through ROS. You can complete an online form or upload an XML file prepared offline, and corrections use the same method as the original submission.

Penalties

Revenue's web pages do not mention penalties, and we do not state any penalty amounts here. The manual does say that, where an intermediary decides an arrangement is not disclosable and that later proves wrong, there is no failure to comply if Revenue is satisfied the decision was reached objectively on all relevant facts and available information. Otherwise it says penalties for non-compliance may apply, with maximums set in the legislation. Check the manual and the legislation for the current position.

Practical steps for Dublin advisory teams

A practical approach for firms in Dublin that advise on cross-border structures:

• screen new engagements against the hallmark categories at the outset, and record the outcome;
• record who the other intermediaries are and whether the Arrangement ID has been shared;
• register for ROS access and a DAC6 reporting obligation before you need to file;
• diarise the 30-day period from the earliest trigger event; and
• train tax and audit staff to recognise the triggers. Our overview of CPD training in Dublin for finance professionals is a starting point for planning that.

Learnsignal's offices are off Baggot Street in Dublin, and we offer in-person training from there. For current details, see our CPD pages.

Frequently asked questions

Who files a DAC6 return in Ireland?

According to Revenue, the intermediary normally files. The relevant taxpayer files where there is no intermediary or where the taxpayer has not waived legal privilege.

How long do I have to file?

Revenue's page says within 30 days of the earliest of the three trigger events described above. Check the current page and manual on the day.

Does legal professional privilege remove the reporting duty?

The manual says an intermediary is exempt for information over which privilege could be maintained, but the intermediary must notify the relevant taxpayer, who then has its own obligation to file.

Where do I file?

Through ROS, either by online form or XML upload, after registering as a reporting entity if needed. Privileged information is filed on Form DAC6 (LPP) through MyEnquiries.

What are the penalties?

We have not covered penalty amounts. The Tax and Duty Manual refers to maximums set in legislation, so check the manual and the legislation directly.

Revenue's DAC6 pages and the Tax and Duty Manual remain the authoritative guides, so read them before relying on this summary.