111AAG Care and management

Details

(1) This subsection provides that the three GloBE taxes (IIR top-up tax, UTPR top-up tax and domestic top-up tax) are all under the care and management of Revenue.

(2) Subsection (2) provides that Part 37 TCA 1997 (administration) shall apply with the necessary modifications detailed below. Part 37 provides the administrative mechanisms necessary to operate the taxation system.

(2)(a) Paragraph (a) contains references to a number of sections in the TCA that are necessary for the operation of the GloBE taxes. To bring these sections into operation for Pillar Two purposes, a modification is necessary to the effect that “corporation tax” shall be read as including a reference to “IIR top-up tax, UTPR top-up tax and domestic top-up tax”.

(2)(b) Paragraph (b) contains references to a number of sections in the TCA that are necessary for the operation of the GloBE taxes. To bring these sections into operation for Pillar Two purposes, a modification is necessary to the effect that “the Tax Acts” shall be read as a reference to this Part.

(2)(c) Paragraph (c) contains a reference to one section in the TCA that is necessary for the operation of the GloBE taxes. To bring this section into operation for Part 4A purposes, a modification is necessary to the effect that “accounting period” shall be read as “fiscal year”.

(2)(d) Paragraph (d) contains a reference to section 865. There are references to chargeable person in section 865 which are referencing the provisions of Part 41A relating to Income Tax, Corporation Tax and Capital Gains Tax. This modification is necessary to ensure the reference to “chargeable person” is read as a reference to ‘qualifying entity’, ‘relevant UTPR entity’ and ‘relevant parent entity’.

(2)(e) Paragraph (e) contains a reference to section 865(1)(a), and in particular the reference to the definition of “chargeable period” which is defined as having the meaning assigned to it in section 321. For the purposes of the operation of Part 4A, the definition of chargeable period in section 865(1)(a) shall be construed as having the same meaning as fiscal year in section 111A.

(2)(f) Paragraph (f) contains a reference to section 870 which is necessary for the operation of the Pillar Two taxes. To bring this section into operation for Pillar Two purposes, a number of modifications are necessary.

Relevant Date: Finance Act 2024