Taxes Consolidation Act 1997 section 817RF

Arrangements implemented before 1 July 2020

Section 817RF extends the mandatory disclosure obligations for reportable cross-border arrangements to cover a "look-back" period from 25 June 2018 to 30 June 2020, with a special filing deadline of 28 February 2021.

• The reporting duties of intermediaries (section 817RC) and relevant taxpayers (section 817RD) apply retrospectively to reportable cross-border arrangements where the first step was implemented between 25 June 2018 and 30 June 2020.
• Returns for arrangements falling within this look-back period were required to be filed with Revenue by 28 February 2021, replacing the normal filing time limits in sections 817RC and 817RD.
• Where an arrangement's first step was implemented during the look-back period but the arrangement was abandoned without having been fully implemented before 28 February 2021, Revenue did not require a return.
• There is no obligation to disclose arrangements where the first step was implemented before 25 June 2018, even if such arrangements remained in place on or after that date.