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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, Greg Lockhart, Catherine O’Meara, Mark O’Sullivan, Liam Quirke, John Ryan, Gerry Thornton
PRACTICE AREA GROUP: Tax, Structured Finance and Securitisation
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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