Revenue Note for Guidance

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Revenue Note for Guidance

111AAAC Transitional simplified jurisdictional reporting

Summary

This section provides that during a transitional period, an election to apply a simplified jurisdictional reporting framework may be made. Provided certain conditions are satisfied, this section allows groups to provide information in the GIR at a jurisdictional level as opposed to a constituent entity by constituent entity level.

Details

Definitions

(1) This subsection provides for the definition of ‘simplified jurisdictional reporting framework’ which is a method of reporting for the purposes of the top-up tax information return, as referenced in the document entitled OECD (2023), Tax Challenges Arising from the Digitalisation of the Economy – GloBE Information Return (Pillar Two), OECD/G20 Inclusive Framework on BEPS, OECD, Paris published by the OECD on 17 July 2023.

General

(2) This section provides that a filing constituent entity can elect to apply simplified jurisdictional reporting framework in respect of the top-up tax information return for a fiscal year in respect of QDTT group members or there is a single qualifying entity, beginning on or before 31 December 2028 and ending on or before 30 June 2030, where

  • (2)(a) all the relevant QDTT members of the MNE group, large-scale domestic group or joint venture group are members of a QDTT group, and the QDTT return for the group has been delivered to Revenue on or before the specified return date, or
  • (2)(b) there is no more than one member of an MNE group or joint venture group, as the case may be, that is a qualifying entity for the fiscal year.

(3) This subsection provides that a filing constituent entity can elect to apply simplified jurisdictional reporting framework in respect of the top-up tax information return for a fiscal year in respect of members of a group located outside the State, beginning on or before 31 December 2028 and ending on or before 30 June 2030 where

  • (3)(a) members of the MNE group, joint venture group are located in a jurisdiction outside the State "other jurisdiction members"),
  • (3)(b) either no charge to IIR top-up tax or UTPR top-up tax arises under this Part in respect of other jurisdiction members, or where a charge arises, that charge is not allocated on an entity-by-entity basis, and
  • (3)(c) under the laws of all jurisdictions in which qualified domestic top-up tax, qualified UTPR or qualified IIR may arise for the fiscal year, the filing constituent entity may complete, in accordance with the simplified jurisdictional reporting framework, the top-up tax information return for the fiscal year, in respect of the other jurisdiction members.

(4) Subsection (2) shall not apply in respect of an investment entity that is not an excluded entity.

Relevant Date: Finance Act 2024