Revenue Note for Guidance

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Revenue Note for Guidance

111AAZ Obligation to keep certain records

Summary

The books and records to be kept by a liable person for the purposes of this Part are set out in this section.

Details

(1) This subsection provides that an entity shall retain or cause to be retained on their behalf, all records to enable a full and true GloBE return and a correct and complete top-up tax information return, to be made under this Part.

(2) This subsection provides that that the records to be retained shall include books, accounts, documents and any other data related to a GloBE return, top-up tax information return and the calculation of GloBE tax.

(3) This subsection provides that the records shall be kept in an official language of the State and in either written form or electronic means.

(4) This subsection provides that any records required to be retained under this section shall be retained for the longer of:

  • (4)(a) the completion of enquiries by a Revenue officer relating to a return submitted, or
  • (4)(b) the period of 6 years commencing from the end of the fiscal year to which the records relate.

(5) This subsection provides that in the case of a company which is:

  • (5)(a) wound up, the liquidator, or
  • (5)(b) is dissolved without the appointment of a liquidator, any person occupying the role of director of the company,

shall retain the records required to be retained for a period of 5 years from the date the company is wound up or dissolved.

(6) This subsection provides for a penalty of €10,000 for failure to retain the records relating to a GloBE return, top-up tax information return and the calculation of GloBE tax.

(7) This subsection provides the Revenue Commissioners with statutory powers of inquiry and inspection with respect to top-up tax information returns to include supporting books, records and information.

The subsection provides that Sections 900 and 901 shall apply, with any necessary modifications—

  1. to records referred to in subsection (1) as if they were books, records or other documents within the meaning of section 900, and
  2. to information, explanations and particulars that the authorised officer, within the meaning of those sections, may reasonably require, being information, explanations and particulars which are related to, or in connection with, a GloBE return or top-up tax information return referred to in subsection (1).

Relevant Date: Finance Act 2025