111AAZ.   Obligation to keep certain records

(1) An entity shall retain, or cause to be retained on behalf of the entity, such records as are required to enable a full and true GloBE return to be made for the purposes of this Part.

(2) Without prejudice to the generality of subsection (1), the records required to be retained under that subsection shall include, but are not limited to, books, accounts, documents (including documents drawn up in the making up of accounts and showing details of the calculations linking the records to the accounts), and any other data relating to a GloBE return and the calculation of GloBE tax.

(3) Records required to be retained under this section shall be retained in an official language of the State—

(a) in written form, or

(b) by means of electronic, photographic or other process in accordance with paragraphs (a) to (d) of section 887(2).

(4) Notwithstanding any other law, records required to be retained under this section shall, subject to subsection (5), be retained by or on behalf of the entity required to retain the records, for the longer of the following periods—

(a) where enquiries into a return are made by a Revenue officer, the period ending on the day on which those enquiries are treated as completed by the officer;

(b) the period of 6 years beginning from the end of the fiscal year to which they relate or, in the case where they relate to more than one fiscal year, the period of 6 years beginning from the end of the later fiscal year.

(5) For the purposes of this section, where the constituent entity—

(a) is wound up, the liquidator, or

(b) is dissolved without the appointment of a liquidator, the last directors, including any person occupying the position of director by whatever name called, of the company,

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

(6) A person who fails to comply with this section in respect of the retention of any records relating to a GloBE return or the calculation of GloBE tax shall be liable to a penalty of €10,000.