The recently published Finance Bill 2016 announced changes to the way in which Section 110 securitisation entities are required to notify Irish Revenue of their intention to be a qualifying Section 110 entity.
The Select Committee Amendments to the Finance Bill which were issued on 4 November, provide further guidance as to the new deadline for filing the notification with Irish Revenue.
The notification must be filed no later than 8 weeks from:
We understand that this new procedure is driven by a focus of the Irish Revenue to develop further oversight on the types of transactions being undertaken by Section 110 entities.
Traditionally, such notifications were made by filing a Form 110 on or before the deadline for the filing of the Section 110 entity’s first Irish corporation tax return i.e. within 9 months of the period end and no later than 23rd day of the month.
Information to be provided as part of the notification procedure
Section 110 entities are now also required to supply additional information concerning:
What should you do now?