On Friday 24 November the Irish Revenue published an eBrief (eBrief No. 107/17) stating that “Due to the late availability of the CbC Reporting filing facility, it will remain open for, and accept, CbC Reports for fiscal years ending in 2016 up to 28 February 2018“.  The first CbC Reports for 2016 were originally due to be filed by relevant taxpayers in Ireland by 31 December 2017.

Please note that this change does not affect the CbC notification requirements, whereby the Regulations require an annual notification to be made to the Irish Revenue by the last day of the fiscal year to which the CbC report relates.

What do you need to do?

1. Check if your entity is in scope

Entities need to check whether they are in scope of CbCR.  Please note that this check must be performed annually.

An entity is in scope in Ireland if it is:

• Part of a multinational organisation,
• operating in Ireland and
• whose consolidated annual revenue for the immediately preceding accounting period exceeds €750 million

2. If your entity is in scope:

Any entity that is in scope in Ireland is required to notify Irish Revenue whether:

• they are the reporting entity of the multinational organisation; or
• if not reporting, who will file the group’s CbC report to include their information i.e. the name and jurisdiction of the reporting entity.

This notification is required to be made on or before 31 December 2017.

For reporting Irish entities

Reports are due to be filed on or before 28 February 2018.

How to file a CbC Notification/Report?

• Notifications are required to be made on ROS.
• CbC reports are required to be filed electronically on ROS and completed in accordance with the OECD CbC Reporting XML Schema. It is expected that the CbC reporting system will be available on ROS in the coming weeks.

Is there a penalty?

Notification: failure to file notifications may result in penalties being issued by Revenue. The notification once made can be amended.

Reporting: failure to file the CbC reports on ROS would result in a fine of €19,045 plus €2,535 for each late day.

How can we help?

EY can assist with the completion/reviewing and filing of CbC reports and also with the notification to the Irish Revenue so please let us know if you require assistance with this.