Financial Services Ireland


Country by Country Reporting – Revenue finalise notification requirements

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As you will be aware Country by Country reporting is in place in Ireland from 1 January 2016.

Irish entities forming part of a multinational group for CbC reporting purposes are required to inform Revenue who will be filing their overall CbC report. The notification is required to be made no later than the last day of the fiscal year to which the CbC report relates i.e. years ending 31 December 2016 need to notify Revenue before 31 December 2016.

In summary, the Irish CbC reporting notification obligations are as follows:

  • Where the ultimate parent entity of the multinational group is tax resident in Ireland, then the ultimate parent entity must notify Revenue that it is the reporting entity.
  • Where a surrogate parent entity has been appointed and that surrogate parent entity is tax resident in Ireland, then that surrogate parent entity must notify Revenue that it is the reporting entity.
  • All other Irish entities forming part of a multinational group must notify Revenue of the name and jurisdiction of tax residence of the reporting entity.

The notification procedure, published by Revenue yesterday, is via Revenue’s Online System (ROS). Registration for CbCR on ROS should be completed prior to making the notification. An agent or an entity can register and file the required notification via ROS.

As before and in line with OECD guidelines there are no industry exemptions included in Ireland’s CbCR regime.  Is your organisation in scope?   If so, do you know who is taking responsibility for the overall CbC report?

To view the latest FAQs please click here.

We expect that for organisations that have not considered their CbC reporting requirements to date this notification procedure should help focus attention.  Further it highlights that where an Irish entity does not have a reporting requirement (i.e. reporting is taking place in another jurisdiction) the Irish entity needs to consider and manage the information that is reported as part of a CbC report as Revenue will receive the information from the foreign tax authority.

Sinéad Colreavy

FS Tax Partner, EMEIA WAM Tax Leader
Sinéad's Full Profile