DAC6 EU mandatory disclosure regime - updates to XSD file and User Guide

Dec 21, 2020

DAC6 provides for the sharing of taxpayer information between tax administrations of EU Member States emanating from the mandatory disclosure of certain cross-border transactions that could potentially be used for aggressive tax planning.  The first reports by taxpayers and intermediaries are due by 31 January 2021.  Revenue recently issued an information notice on XML files.

Revenue’s DAC6 XSD file and the DAC6 XSD User Guide are available on the Revenue website. The following should be noted:

  • The DAC6 XSD file has been amended so that the DisclosureID field will not be mandatory where a DisclosureID has not been issued previously, whether by Revenue or the Competent Authority of another Member State.
  • The DAC6 User Guide has been amended to clarify that Revenue will issue an ArrangementID and/or DisclosureID for each filing where an ArrangementID and/or DisclosureID has not been issued previously.
  • Where a DAC6 Return is filed by uploading an XML file, the submission should be filed using the updated DAC6 XSD file (converted to an XML file).

See Revenue’s webpage and Tax and Duty Manual (TDM) Part 33-03-03 for more information on DAC6.  At a recent TALC meeting, Revenue confirmed that this TDM will be updated shortly to reflect guidance on Hallmark Category C.