Taxes Consolidation Act 1997 section 111AAAA

Use of currency

Section 111AAAA sets out the rules on which currency must be used when calculating the various GloBE top-up taxes, how foreign currency amounts are to be converted, and the currency in which payments must be made to the Revenue Commissioners.

• IIR top-up tax and UTPR top-up tax must be calculated in the presentation currency of the ultimate parent entity's consolidated financial statements, with any unconverted foreign currency amounts translated using the same accounting standard principles that would apply during consolidation.
• Euro-denominated thresholds in Part 4A are tested by converting other currencies to euro using the average daily exchange rate for December of the fiscal year immediately preceding the year in question, sourced from the European Central Bank, the Central Bank of Ireland, or an equivalent institution.
• Domestic top-up tax calculations are made in euro where all qualifying entities in the State use a local accounting standard with a euro functional currency; otherwise, an election may be made to use either the ultimate parent entity's presentation currency or the euro, and where no local accounting standard applies, the ultimate parent entity's presentation currency is used.
• All payments due to the Revenue Commissioners under Part 4A must be made in euro, with any amount denominated in another currency converted using the average representative exchange rate for the fiscal year or accounting period.