817M Duty of promoter to provide client list

This section requires a promoter to provide the Revenue Commissioners, at regular intervals (set out in the regulations), with information on persons to whom a disclosable transaction has been made available for implementation. This list is known as the client list and the list has to be specific to each disclosable transaction made available. The timing of the initial provision of this client list will, by definition, be linked to when a scheme is made available to clients for implementation and so could not be provided at the time the transaction is disclosed to Revenue where that disclosure date (i.e. relevant date) is the date of a marketing contact. The promoter will be expected to continue to provide Revenue with updated client lists at quarterly intervals after the initial list is made available so that usage of a scheme/transaction can be monitored. The identification details of clients need not be provided to Revenue where at the time the client list has to be furnished, the promoter is satisfied that the client has not implemented the transaction. However, the details must be furnished subsequently when the client has, in fact, implemented the transaction.

Relevant Date: Finance Act 2021