111AAP.   QDTT group recovery

(1) (a) In this section “authorised officer” means an officer of the Revenue Commissioners authorised by them in writing to exercise the powers conferred by this section.

(b) For the purposes of this section any reference to an amount of domestic top-up tax shall be construed as including a reference to any interest, surcharge or penalty relating to such an amount.

(2) This section shall apply where domestic top-up tax payable by a QDTT group filer in respect of a fiscal year is not paid within 12 months after the date on or before which the domestic top-up tax is due and payable.

(3) (a) An authorised officer may, at any time before the end of the period—

(i) beginning with the date that is 12 months after the date on which the domestic top-up tax is due and payable, and

(ii) ending 4 years after the date on which the domestic top-up tax is due and payable,

serve on a relevant QDTT member of a QDTT group for the fiscal year (hereinafter referred to as the ‘specified relevant QDTT member’), a notice in writing—

(I) stating the amount which remains unpaid of the domestic top-up tax payable and the date on which the tax became due and payable, and

(II) requiring the specified relevant QDTT member to pay that amount within 30 days of service of the notice,

and, where such a notice is served, the amount referred to in clause (I) shall be so payable by the specified relevant QDTT member.

(b) Any amount which a specified relevant QDTT member is required to pay pursuant to a notice under this subsection may be recovered from the specified relevant QDTT member as if it were tax due by that specified relevant QDTT member, and that specified relevant QDTT member may recover any such amount paid pursuant to a notice under this subsection from the QDTT group filer.

(c) Where the amount of tax included in a notice served under this subsection is not paid in full by the specified relevant QDTT member, an authorised officer may—

(i) revoke the notice served, and

(ii) serve a notice under this section on another relevant QDTT member until the full amount of tax due and payable is paid.