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Irish CbC Reporting for Multinational Groups, Irish Investment Funds and Irish SPVs

AUTHOR(S): Christian Donagh, Joe Duffy, Aidan Fahy, Catherine Galvin, Turlough Galvin, Shane Hogan, Alan Keating, John Kelly, Greg Lockhart, Catherine O’Meara, Mark O’Sullivan, Liam Quirke, John Ryan, Gerry Thornton
PRACTICE AREA GROUP: Tax, Structured Finance and Derivatives
DATE: 04.02.2016

Ireland’s country by country (“CbC”) reporting regulations (the “Regulations”) were published in January 2016. The Regulations include important details on when Irish subsidiaries of non-Irish headquartered groups will be obliged to file CbC reports with the Irish Revenue Commissioners (“Irish Revenue”).  In this Tax update, we outline:

  • the application of CbC reporting to Irish headquartered groups and Irish subsidiaries of non-Irish headquartered groups;
  • the impact of the Regulations on international groups that include Irish investment funds and SPVs;
  • the notification obligations that for many international groups will apply during 2016;
  • the penalties for failure to comply; and
  • the progress Ireland has so far made in concluding arrangements to exchange Irish CbC reports with other jurisdictions.

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