(1) Part 33 of the Principal Act is amended by inserting the following Chapter after Chapter 3:

"Chapter 3A Implementation of Council Directive (EU) 2018/822 of 25 May 2018 [OJ No. L139, 5.6.2018, p.1] amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation in relation to reportable cross-border arrangements

817RA. Interpretation (Chapter 3A)

(1) In this Chapter -

'arrangement' means -

(a) any transaction, action, course of action, course of conduct, scheme, plan or proposal,

(b) any agreement, arrangement, understanding, promise or undertaking, whether express or implied and whether or not enforceable or intended to be enforceable by legal proceedings, and

(c) any series of or combination of the circumstances referred to in paragraphs (a) and (b),

whether entered into or arranged by one or two or more persons -

(i) whether acting in concert or not,

(ii) whether or not entered into or arranged wholly or partly outside the State, or