According to eBrief No. 26/09, a series of answers to Frequently Asked Questions in relation to Third Party Reporting of settlements involving non-resident trustees has been published on the Revenue website.
The FAQs are available here
We wish to draw your attention to the following FAQ:
"Where a tax practitioner provides taxation services in relation to the establishment of an offshore trust for a client, but the practitioner is unaware as to whether the funds were actually settled - is a return required?
Yes. The service is specific to a client or trustee and the tax practitioner is involved in the making of the settlement and a return is required."
Clarification was sought at the recent Main TALC meeting on this question, as it seems to go beyond the scope of the new TCA97 s896A, but the matter is not fully resolved