Taxes Consolidation Act 1997 section 817F

Duty of person where promoter is outside the State

Section 817F requires a person who enters into a disclosable transaction to provide specified information to Revenue where the promoter of the transaction is outside the State and no promoter is within the State.

• Where a promoter of a disclosable transaction is outside Ireland and no promoter is within the State, the disclosure obligation shifts from the promoter to the person entering into the transaction.
• The person must provide Revenue with specified information relating to the disclosable transaction within 5 working days after the specified date.
• The specified date is determined by reference to the date of the first transaction entered into by the user that forms part of the disclosable transaction.
• This is one of three situations (along with legal professional privilege and in-house schemes) where the disclosure obligation falls on the scheme user rather than the promoter.