The formal guidelines for the Mandatory Disclosure of Certain Transactions legislation introduced in Section 149 Finance Act 2010 is still awaited. The Irish Taxation Institute has made a detailed submission to Revenue on the initial consultation paper and draft regulations published by Revenue and concern has been expressed by the Institute on many issues including:- 

  • The need to carve-out day to day tax advice and for this to be enshrined in the body of the Regulations and a focus given to what is being sought under the regime.
  • Reporting can only take place on a “going forward” basis once the Regulations are finalised – reports required on transactions which have happened in the past, without any clear guidance of the rules at that time, are unworkable.



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