Revenue has published draft amended mandatory disclosure regime guidance notes and regulations to reflect the changes to the regime announced in the Finance Bill.
The changes to the mandatory disclosure regime apply to transactions commenced after 23 October 2014. There are practical difficulties in implementing the new requirements in the time required and in the absence of new guidance. Revenue has confirmed that disclosures made by 31 January 2015, for transactions commenced after 23 October 2014, will be accepted as made on time.
This firm has made submissions in relation to the inclusion of discretionary will trusts in the regime as being inappropriate in the context of a Will not being binding until death.
