Revenue Note for Guidance

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Revenue Note for Guidance

111AAH Obligation to register

Summary

This section sets out the obligation on constituent entities within scope of the GloBE taxes to notify Revenue.

Details

Registration

(1)(a) An entity that is subject to IIR top-up tax for a fiscal year (in this Chapter referred to as a ‘relevant parent entity’), shall give notice to the Revenue Commissioners, in the form and manner specified by the Revenue Commissioners, that it is such an entity, not later than:

  1. the last day of the period of 12 months starting on the day immediately following the last day of the first fiscal year during which it is a relevant parent entity, immediately following a fiscal year for which it was not a relevant parent entity (in this paragraph referred to as the ‘IIR registration date’), or
  2. 31 December 2025, where the IIR registration date is earlier than 31 December 2025.

(1)(b) An entity that is subject to UTPR top-up tax for a fiscal year (in this Chapter referred to as a ‘relevant UTPR entity’) shall give notice to the Revenue Commissioners in the form and manner specified by the Revenue Commissioners, that it is such an entity, not later than:

  1. the last day of the period of 12 months starting on the day immediately following the last day of the first fiscal year during which it is a relevant UTPR entity, immediately following a fiscal year for which it was not a relevant UTPR entity (in this paragraph referred to as the ‘UTPR registration date’), or
  2. 31 December 2025, where the UTPR registration date is earlier than 31 December 2025.

(1)(c) A qualifying entity shall give notice to the Revenue Commissioners, in the form and manner specified by the Revenue Commissioners, that it is such an entity, not later than:

  1. the last day of the period of 12 months starting on the day immediately following the last day of the first fiscal year that it is a qualifying entity, immediately following a fiscal year for which it was not a qualifying entity (in this paragraph referred to as the ‘QDTT registration date’), or
  2. 31 December 2025, where the QDTT registration date is earlier than 31 December 2025.

Notice Information

(2) This subsection lists the information that is required on a notice under subsection (1). The notice shall contain:

  • (2)(a) the name of the entity,
  • (2)(b) the TIN of the entity,
  • (2)(c) the tax or taxes in respect of which the entity in registering,
  • (2)(d) where the entity is a member of an MNE group or a large-scale domestic group:
    1. the name of the ultimate parent entity,
    2. the location of the ultimate parent entity, and
    3. the TIN of the ultimate parent entity,
  • (2)(e) the details of the first fiscal year that the entity is a relevant parent entity, relevant UTPR entity or qualifying entity, as the case may be,
  • (2)(f) where an entity has been appointed as the designated filing entity on behalf of the MNE group or the large-scale domestic group of which the entity is a member:
    1. the name of the designated filing entity,
    2. the location of the designated filing entity; and
    3. the TIN of the designated filing entity,
  • (2)(g) where the entity is a member of an MNE group or a large-scale domestic group and an entity has been appointed by the entity and other constituent entities of the group located in the State as the designated local entity:
    1. the name of the designated local entity, and
    2. the TIN of the designated local entity,
  • (2)(h) where the entity is a member of an MNE group or a large-scale domestic group and the entity has been appointed by other constituent entities of the group located in the State as the designated local entity:
    1. the names of the other constituent entities, and
    2. the TINs of the other constituent entities,
  • (2)(i) where the entity is a member of an MNE group, large-scale domestic group or joint venture group and the entity and all of the relevant QDTT members of the group elect to be members of a QDTT group:
    1. notice in writing of the election to become a member of the QDTT group,
    2. the name of the QDTT group filer,
    3. the TIN of the QDTT group filer, and
    4. where the entity is the QDTT group filer, notification that it is the QDTT group filer,
  • (2)(j) where the entity is a member of an MNE group and the entity and all of the relevant UTPR members of the group elect to be members of a UTPR group:
    1. notice in writing of the election to become a member of the UTPR group,
    2. the name of the UTPR group filer,
    3. the TIN of the UTPR group filer, and
    4. where the entity is the UTPR group filer, notification that it is the UTPR group filer,

    and

  • (2)(k) such other information as the Revenue Commissioners may reasonably require for the purpose of Part 4A.

Change of Registration

(3) This subsection provides that an entity shall notify the Revenue Commissioners of any change to the information provided in accordance with subsection (2) within 12 months of the end of the fiscal year in which the change occurred.

Cessation of registration

(4) The subsection provides for the cessation of a registration where an entity is no longer a qualifying entity, a relevant UTPR entity or a relevant parent entity. The entity shall notify Revenue within 12 months of the end of the first fiscal year is not such an entity immediately following a fiscal year in which the entity was such an entity.

Penalties

(5) This subsection provides a penalty for failure to submit the notice required under this section. The penalty is €10,000.

(6) This subsection provides a penalty for failure to comply with requirements under subsection (3) or (4). The penalty is €10,000.

Relevant Date: Finance Act 2024