Thursday, 19 January 2017

Ireland's Tax authorities issue more updated guidance on CbC reporting

Ireland’s tax authorities (Irish Revenue) updated their guidance on country-by-country (CbC) reporting on 9 December 2016. The update includes some technical amendments and clarifications to assist companies in understanding their CbC reporting obligations in Ireland. It also is a reminder for Irish resident constituent entities of a multinational group within the remit of CbC reporting that notification must be made to Irish Revenue before 31 December 2016 if the
accounting year-end for CbC reporting purposes is 31 December 2016.
The main changes from the last update on 13 October 2016 are as follows:

  • Clarification that where there is more than one Irish resident constituent entity in a group, one entity may be nominated to notify on behalf of other Irish resident constituent entities. This nomination option is available only where the secondary reporting mechanism does not take place, i.e. local filing of a CbC report. In effect, the nomination option can be used only where the CbC report for the group is filed by an ultimate parent or appointed surrogate parent.
  • Irish Revenue acknowledges that at the time the Irish constituent entity of a group provides notification, the identity of the group company that is the reporting entity may not be known. This can occur for a number of reasons, including where a jurisdiction has not yet formally introduced CbC reporting or the relevant competent authority agreement is not yet in place. As a transitional arrangement, Irish Revenue will allow Irish resident constituent entities to provide notification based upon a preliminary assessment of the identity and tax residence of the reporting entity for the group. To the extent this identity subsequently changes, a corrected notification can be made.
  • Some minor amendments are included in Appendix III of the guidance notes, which contain the step-by-step guide to providing notification by companies or their agents on the ROS platform including a new email contact for queries relating to the CbC reporting notification procedure. 

Source & more info: Deloitte