111AAH.   Obligation to register

(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 12 months after 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.

(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 12 months after 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.

(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 12 months after 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.

(2) A notice under subsection (1) shall contain—

(a) the name of the entity,

(b) the TIN of the entity,

(c) the tax or taxes in respect of which the entity is registering,

(d) where the entity is a member of an MNE group or a large-scale domestic group—

(i) the name of the ultimate parent entity,

(ii) the location of the ultimate parent entity, and

(iii) the TIN of the ultimate parent entity,

(e) 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,

(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—

(i) the name of the designated filing entity,

(ii) the location of the designated filing entity, and

(iii) the TIN of the designated filing entity,

(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—

(i) the name of the designated local entity, and

(ii) the TIN of the designated local entity,

(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—

(i) the names of the other constituent entities, and

(ii) the TINs of the other constituent entities,

(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—

(i) notice in writing of the election to become a member of the QDTT group,

(ii) the name of the QDTT group filer,

(iii) the TIN of the QDTT group filer, and

(iv) where the entity is the QDTT group filer, notification that it is the QDTT group filer,

(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—

(i) notice in writing of the election to become a member of the UTPR group,

(ii) the name of the UTPR group filer,

(iii) the TIN of the UTPR group filer, and

(iv) where the entity is the UTPR group filer, notification that it is the UTPR group filer,

and

(k) such other information as the Revenue Commissioners may reasonably require for the purposes of this Part.

(3) Where there is any change to the information provided under subsection (2) the entity shall notify the Revenue Commissioners of the change within 12 months of the end of the fiscal year in which the change occurred.

(4) Where an entity ceases to be a qualifying entity, relevant UTPR entity or relevant parent entity, as the case may be, the entity shall notify the Revenue Commissioners of the cessation within 12 months of the end of the first fiscal year in which the entity is not such an entity immediately following a fiscal year in which the entity was such an entity.

(5) Where an entity fails to give notice to the Revenue Commissioners in accordance with subsection (1) the entity shall be liable to a penalty of €10,000.

(6) Where an entity fails to comply with subsection (3) or (4) that constituent entity shall be liable to a penalty of €10,000.