Revenue Note for Guidance

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Revenue Note for Guidance

817Y Reporting

Summary

This section sets out the reporting requirements for Irish companies, and non-resident companies carrying on a trade in the State through a branch or agency, paying relevant interest or royalties, and making relevant distributions, to associated entities who are resident, or situated, is specified territories.

Details

(1) The terms “chargeable period” and “specified return date for the chargeable period” have the meaning assigned to them by section 959A.

(2) Every company who makes a payment of interest or a royalty, or makes a relevant distribution to—

  • (2)(a) an associated entity that is resident in a specified territory and is not resident in another territory that is not a specified territory, or
  • (2)(b) a permanent establishment of an associated entity which is situated in a specified territory,

in a chargeable period shall, in the return required to be delivered under Chapter 3 of Part 41A, provide the following details in respect of each payment or distribution—

  • (2)(b)(i) the amount of the payment or distribution,
  • (2)(b)(ii) the amount of tax withheld on the payment or distribution, and
  • (2)(b)(iii) the territory where the entity or permanent establishment is resident, or situated, as the case may be.

It is important to note that the reporting requirement applies to all payments of interest or royalties, or distributions made, to an associated entity, or a permanent establishment of an associated entity, which is resident or situated in a specified territory as the case may be.

Relevant Date: Finance Act 2024