Revenue eBrief No. 031/26

04 February 2026

Automatic Exchange of Information

This eBrief is to inform customers of changes made to Tax and Duty Manual (TDM)  Part 35-01-01a and subsequent changes to TDM Part 38-03-35.

• Paragraph 3.5.1 on DAC3 has been updated to include the expansion of DAC3 to include certain cross-border tax rulings involving natural persons (individuals) from 1 January 2026. From 1 January 2026, DAC8 requires advance cross‑border tax rulings issued to individuals to be exchanged with EU tax authorities, if the ruling relates to whether the individual is tax resident in the issuing Member State, or if the amount of the transaction/series of transactions exceeds €1,500,000 (or equivalent in another currency) and that amount is referred to in the ruling.

Other changes to TDM 35-01-01a have been made as follows:

• Paragraph 3.2.2 of TDM 35-01-01a has been updated to remove reference to DAC2/CRS exchanges taking place under the Ireland - Hong Kong DTA. These exchanges are now made under The Convention. Paragraph 4.1 of TDM 38-03-35 has also been deleted to reflect this change.
• Paragraph 3.2.2 of TDM 35-01-01a have been amended to make the restrictions of the use of data exchanged under the Convention clearer.
• Paragraph 3.9 has been added to cover the Exchange Of Information On Crypto Asset Transactions under CARF and DAC8.
• Appendix 1 has been updated to include new exchange relationships.