DAC8 Reporting in Ireland: Practical Guide

Ireland, as a major financial services centre in the EU, hosts a significant number of crypto-asset service providers and fintech companies. The Irish Revenue Commissioners are expected to administer DAC8 reporting obligations, building on the country's established infrastructure for international tax information exchange. This guide covers the practical aspects of DAC8 reporting for entities operating in Ireland.

National Authority

The Office of the Revenue Commissioners (commonly known as Revenue) is the competent authority for tax administration in Ireland, including international exchange of information under CRS, FATCA, and other frameworks. Revenue is expected to be responsible for receiving and processing DAC8 reports from crypto-asset service providers. The Department of Finance oversees the legislative transposition of EU tax directives into Irish law.

Submission Requirements

Ireland has a modern, digitised tax administration system, and DAC8 submissions are expected to be handled through Revenue's electronic channels.

• Format: Reports should follow the OECD CARF XML schema as specified by DAC8. Revenue may publish additional technical guidance and XML schema documentation specific to Ireland.
• Language: Tax filings in Ireland are conducted in English (and/or Irish). Given that English is the primary language of administration, reporting entities should generally not face language barriers. Data fields should follow international standards.
• Submission channel: Revenue's Online Service (ROS) is the primary platform for electronic tax filings in Ireland. DAC8 reporting may be integrated into ROS or handled through a dedicated submission channel. The exact method is to be confirmed by Revenue.
• Tax reference number: Reporting entities will typically need an Irish tax reference number and ROS registration to submit filings.

Transposition Status

Ireland must transpose the DAC8 directive into national law by December 31, 2025. The transposition is typically achieved through a Finance Act or a statutory instrument (SI). The Department of Finance is responsible for drafting the legislation, with input from Revenue on operational aspects. Ireland has generally maintained a good track record for transposing EU tax directives in a timely manner.

Local Variations

Ireland may introduce certain national-specific elements in its DAC8 implementation:

• Central Bank registration: Crypto-asset service providers operating in Ireland are subject to registration with the Central Bank of Ireland under anti-money laundering regulations. DAC8 obligations may be coordinated with this regulatory framework, transitioning to MiCA authorisation.
• Capital gains tax alignment: Ireland taxes crypto-asset gains under Capital Gains Tax (CGT) at a rate that is well known to practitioners. DAC8 data may be used to verify CGT compliance.
• International financial centre considerations: Given Ireland's role as a base for many international financial services firms, Revenue may provide specific guidance for entities serving clients across multiple jurisdictions.
• Self-assessment interaction: DAC8 data may be cross-referenced with individual self-assessment tax returns to verify reported crypto-asset gains and disposals.

Key Dates

• Transposition deadline: December 31, 2025 (directive must be incorporated into Irish law)
• Data collection begins: January 1, 2026 (reporting entities should start collecting relevant information)
• First reporting period: Calendar year 2026
• First reports due: 2027 (exact date to be confirmed by Revenue; likely to align with existing international exchange timelines)

Practical Tips

• Register for ROS early: If you are a new reporting entity, ensure you are registered with Revenue and have ROS access well before the reporting deadline.
• Monitor Revenue eBriefs: Revenue publishes eBriefs and Tax and Duty Manuals that provide operational guidance. Watch for DAC8-specific publications.
• Leverage CRS experience: If your entity already reports under CRS through Revenue, use that experience and infrastructure as a starting point for DAC8 compliance.
• Engage with Revenue's Large Corporates Division: If you are a significant reporting entity, Revenue's Large Corporates Division may provide direct engagement opportunities.
• Maintain robust due diligence records: Revenue expects reporting entities to maintain adequate records of their due diligence processes. Document all steps taken to identify reportable persons and transactions.
• Seek professional advice: Consider engaging Irish tax advisors or solicitors with expertise in international tax reporting and digital assets.

Important Notice

This guide provides general information about DAC8 reporting in Ireland. Requirements may change as the directive is transposed into national law. The information presented here should not be considered definitive legal or tax advice. Always consult the Office of the Revenue Commissioners and the Department of Finance for the latest official requirements. For specific compliance questions, seek advice from qualified Irish tax professionals.