111AAF Interpretation

Details

Definitions

(1) Introduces definitions relating to the administration of this Part.

“assessment” means an assessment to GloBE tax made under this Part. It includes a Revenue assessment or self-assessment, unless the context otherwise requires;

“designated local entity” means the constituent entity of an MNE group or large-scale domestic group that is located in Ireland that has been appointed by the other constituent entities of the group to file the top-up tax information return or submit the notification of filer on their behalf;

“electronic means” is defined in section 917EA, i.e. includes electrical, digital, magnetic, optical, electromagnetic, biometric, photonic means of transmission of data and other forms of related technology by means of which data is transmitted;

“GloBE return” means an IIR return, a UTPR return or QDTT return;

“GloBE tax” means IIR top-up tax, UTPR top-up tax or domestic top-up tax;

“IIR return” has the meaning assigned to it in section 111AAJ;

“IIR self-assessment” means an assessment by a relevant parent entity, or a person acting under the authority of a relevant parent entity, of the amount of IIR top-up tax payable by the relevant parent entity for the fiscal year;

“notification of filer” is defined in section 111AAI;

“prescribed form” means a form prescribed by the Revenue Commissioners for the purpose of this Part;

“QDTT group” has the meaning assigned to it in section 111AAO;

“QDTT group filer” has the meaning assigned to it in section 111AAO;

“QDTT return” has the meaning assigned to it in section 111AAN;

“QDTT self-assessment” means an assessment by a qualifying entity, or a person acting under the authority of a qualifying entity, of the amount of domestic top-up tax payable by the qualifying entity for the fiscal year;

“qualifying entity” is defined in section 111AAB;

“relevant parent entity” is defined in section 111AAH;

“relevant UTPR entity” is defined in section 111AAH;

“Revenue assessment” has the meaning assigned to it in section 111AAU;

“specified return date” in respect of a fiscal year, means, subject to subsection (5):

1. the last day of the period of 15 months beginning on the day immediately following the end of the fiscal year, or
2. where the fiscal year is a transition year, the last day of the period of 18 months beginning on the day immediately following the end of the fiscal year;

“TIN” is the tax identification number assigned by the Revenue Commissioners to a constituent entity, or where a constituent entity is not located in Ireland, the equivalent number assigned in the jurisdiction in which it is located;

“top-up tax information return” is defined in section 111AAI;

“transition year” is the first fiscal year that a qualifying entity, a relevant UTPR entity or a relevant parent entity, as the case may be comes within scope of this Part;

“UTPR group” has the meaning assigned to it in section 111AAL;

“UTPR group filer” has the meaning assigned to it section 111AAL;

“UTPR return” has the meaning assigned to it in section 111AAK;

“UTPR self-assessment” means a relevant UTPR entity’s assessment, or a person acting under the authority of a relevant UTPR entity, to an amount of domestic top-up tax payable by the relevant UTPR entity for the fiscal year.

(2) This provision provides that all notifications, notices, returns or other such documentation required under this Part must be delivered by electronic means and the relevant provisions of Chapter 6 of Part 38 apply.

(3) For the purposes of this Chapter a reference to ‘entity’ shall be construed as including a reference to a permanent establishment.

(4) For the purposes of this Chapter a reference to ‘fiscal year’ shall be construed as including a reference to an accounting period in respect of an entity to which section 111AAB(1)(c) applies.

(5) For the purpose of the definition of ‘specified return date’ in subsection (1), where the specified return date of an entity or group would otherwise arise before 30 June 2026, the specified return date of that entity or group shall instead be 30 June 2026.

Relevant Date: Finance Act 2024