On 1 January 2016, Ireland’s new Country-by-Country (CbC) reporting requirements took effect. The Irish CbC requirements require certain Irish parented groups, and in specific instances, domestic subsidiaries of foreign parented groups, to report data on revenues, profits, taxes paid/accrued, employee numbers, along with other data on a country-by-country basis for the group to the Revenue Commissioners. Groups with annual consolidated revenue in the preceding accounting period of less than €750 million will be exempt from the CbC reporting requirements. The deadline to file the CbC report with the Revenue Commissioners is 12 months from the end of the relevant accounting period.
Irish corporate taxpayers should be aware of the fast approaching CbC notification deadline of 31 December 2016 (for calendar year ended companies) which requires Irish companies to notify the Revenue Commissioners electronically to confirm the identity and tax residence of the CbC reporting entity.
The Irish regulations require an annual notification to be made to the Revenue Commissioners by the last day of the fiscal year to which the CbC report relates. A detailed step by step guidance on how to make the electronic notification is included in the CbC reporting FAQ published by the Revenue Commissioners on 9 December 2016. The updated guidance confirms that jurisdictions have flexibility as to the due date for the submission of CbC reporting notifications.