Revenue have now issued the Mandatory Disclosure guidelines to account for the changes to this regime under Finance Act 2014. See also here.

We welcome that this firm's submissions have been taken into account in connection with the list of routine tax advice, routine use of exemptions and reliefs in the context of discretionary will trusts as set out in Appendix 1. However we still have a concern that a discretionary trust created under a Will could be disclosable on the making of the Will itself and not on death on the basis that the trust is only an enforceable trust on death.  Given that any trust established under the laws of Ireland where the trustees are resident in Ireland will not be disclosable however, this should not affect the majority of Wills created in Ireland.