Taxes Consolidation Act 1997 section 817RD

Duties of relevant taxpayer

Section 817RD sets out the obligations of a relevant taxpayer to file returns of specified information in respect of reportable cross-border arrangements, including the time limits for filing, exemptions from filing, and the duty to include the arrangement reference number in the annual tax return.

• Where there is no intermediary, or the intermediary is exempt from filing due to legal professional privilege, the relevant taxpayer must file a return of the specified information electronically within 30 days of the arrangement being made available or ready for implementation, or of the first implementation step being taken, whichever occurs first.
• Where more than one relevant taxpayer is involved, the return is made by the taxpayer that agreed the arrangement with the intermediary or, failing that, the taxpayer that manages implementation; the filing taxpayer must share the arrangement reference number with all other relevant taxpayers within five working days.
• A relevant taxpayer is exempt from filing if they receive written confirmation from an intermediary or another relevant taxpayer that the specified information has been returned to Revenue (or to another EU Member State's competent authority), together with the reference number assigned to the arrangement.
• Any person who obtains or seeks to obtain a tax advantage from a reportable cross-border arrangement is a chargeable person for self-assessment purposes and must include the arrangement reference number in their return of income for each chargeable period in which a relevant transaction occurs or the advantage is sought.