Finance (No.2) Act 2008 introduced a new reporting requirement for accountants and other agents concerned with the setting up of offshore settlements. The new provisions are broad in scope, and could create a significant additional reporting burden. Following discussions last month with Revenue, no reports will be required under this section until 1 September next.

Under TCA07 s896A, reports must be provided on details of settlements where the settlor is Irish resident but the trustees are not. These reports are required on an ongoing basis within four months of the making of the settlement. The first such reports would therefore be due around now.

The extension has been granted by Revenue to allow the professional bodies to work with Revenue in scoping out the extent of the reporting requirement, thus ensuring that Revenue don't have to deal with duplicate reporting while taxpayers and their agents don't have an unnecessary compliance burden.

We understand that Revenue will confirm this extension arrangement in a forthcoming eBrief – the eBrief (29/09) was issued on Friday May 8 and is reproduced at Section 2.03.

A separate reporting requirement under s896A, involving settlements made five years prior to Finance (No.2) Act 2008, has already been extended to 1 September.