Taxes Consolidation Act 1997 section 817REA

Revenue powers

Section 817REA sets out Revenue's powers of enquiry into compliance by intermediaries and taxpayers with their obligations under the mandatory disclosure rules for cross-border arrangements (DAC6), including access to anti-money laundering data.

  • An authorised officer may enter the premises of an intermediary or relevant taxpayer to check the accuracy and completeness of DAC6 returns, and where legal professional privilege applies, enquiries are limited to verifying the intermediary advised the taxpayer of their filing obligation.
  • Where an enquiry concerns a cross-border arrangement involving Hallmark D (automatic exchange of information and beneficial ownership), an authorised DAC officer may access anti-money laundering documentation, beneficial ownership registers, and the Central Mechanism of Ownership of Bank and Payment Accounts and Safe-Deposit Boxes.
  • An authorised DAC officer may require a designated person to deliver anti-money laundering information within a specified period of not less than 14 days, and the beneficial owner must be notified in writing when a register is accessed or information is requested.
  • Access to register and anti-money laundering information is subject to the Data Protection Act 2018, and the relevant Registrars and the Central Bank of Ireland must afford an authorised DAC officer timely access on request.

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