DAC7/MRDP

Overview

Council Directive 2011/16/EU (DAC) provides for the exchange of taxpayer information between the tax administrations of European Union (EU) Member States. In 2021, the DAC was amended by Council Directive (EU) 2021/514 (DAC7).

The Model Reporting Rules for Digital Platform Operators (MRDP) is the agreed standard for the Automatic Exchange of Information (AEOI) on digital platform operators. It was approved by the Organisation for Economic Co-operation and Development (OECD) in June 2020. Ireland is one of the jurisdictions that have signed up to the MRDP.

DAC7 and the MRDP oblige digital platform operators to collect and report information on certain sellers using their platforms to earn consideration.

MRDP and DAC7 obligations apply to platforms that allow registered sellers to connect with customers for the provision of the following services for consideration:

• The sale of goods.
• The rental of immovable property (for example, accommodation).
• The provision of personal services (time-, or task-based, work carried out either online, or physically offline, after having been facilitated via a platform).
• The rental of any mode of transport.

The above are referred to as a ‘Relevant activity’.

Irish legislation on MRDP and DAC7

DAC7 and the MRDP were transposed into Irish law by Section 891I and Section 891J of the Taxes Consolidation Act (TCA), 1997, respectively.

These are supported by Regulations:

• S.I. No. 705 of 2022
• S.I. No. 674 of 2023.

When, and how, information is exchanged with other jurisdictions

Under the legislation set out above, platform operators must file a return by 31 January in respect of the previous calendar year. A platform operator must, by 31 January, provide a reportable seller with a copy of their information included in the return.

Revenue will exchange reported information with the relevant jurisdictions by the end of February. Data exchanged with other Member States is done so under DAC7 and with third countries under the MRDP.

The first reporting of information under DAC7 was in respect of the calendar year 2023. From 2025 onwards, Revenue also exchanged information with the following jurisdictions under the MDRP:

• Canada
• New Zealand
• The United Kingdom (UK).

Revenue has published a list of reportable jurisdictions for the MRDP and DAC7.

Next: Registration obligations for platform operators