Revenue has published updated guidance on the automatic exchange of information between tax administrations to provide details of the expansion of DAC3 and other further clarifications.
The updates to the guidance are as follows:
- Paragraph 3.5.1 has been updated to reflect the expansion of DAC3 from 1 January 2026 to include certain cross-border tax rulings involving natural persons.
The paragraph also outlines that from 1 January 2026, DAC8 requires advance cross‑border tax rulings issued to individuals to be exchanged with EU tax authorities. This applies when the ruling concerns the individual’s tax residency in the Member State issuing the ruling, or when the value of the transaction or series of transactions exceeds €1,500,000 (or the equivalent in another currency) and that amount is referenced in the ruling.
- Paragraph 3.2.2 has been updated to remove reference to DAC2/CRS exchanges taking place under the Ireland - Hong Kong DTA as these exchanges are now made under The Convention. Paragraph 4.1 has also been deleted to reflect this change. Paragraph 3.2.2 has been revised to clarify the restrictions on the use of data exchanged under the Convention.
- Details regarding the exchange of information on crypto asset transactions under the Crypto-Asset Reporting Framework (CARF) and DAC8 have been included in paragraph 3.9.
- Appendix 1 has been updated to include new exchange relationships.
As a consequence of these changes, the guidance on returns in relation to foreign accounts has been updated accordingly.
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