Ireland: Country-by-country legislation is enacted

The president of Ireland on 22 December 2015 signed into law Finance Act 2015 that includes rules following the OECD’s recommended country-by-country (CbyC) reporting requirements. The Finance Act provision closely mirrors the OECD’s suggested model legislation.

For fiscal years beginning on or after 1 January 2016, multinational groups whose ultimate parent entity is a tax resident in Ireland will have to file an annual CbyC report with the Irish Revenue Commissioners if the group’s consolidated turnover exceeds €750 million. These multinational groups will be required to file their CbyC reports no later than 12 months after the end of the relevant fiscal year.

Further regulations are expected to be issued by the Revenue Commissioners in connection with CbyC reporting for large Irish head-quartered multinational groups. These regulations will address, among other items, a requirement for Irish tax resident subsidiaries to:

• Provide a CbyC report to the Revenue Commissioners to the extent the ultimate parent entity is not obligated to file a CbyC report in its country of residence, or
• Notify the Revenue Commissioners of CbyC reports filed with foreign tax authorities