Taxes Consolidation Act 1997 section 111AAAB

Penalties

Section 111AAAB sets out the penalties that apply where constituent entities of MNE groups or large-scale domestic groups fail to meet their filing and compliance obligations under the GloBE (Global Anti-Base Erosion) top-up tax rules, and provides for transitional penalty relief during the early years of the regime.

• A constituent entity that fails to file a top-up tax information return or notification of filer by the due date faces a penalty of €10,000 per complete month of delay, up to a maximum of 48 months (€480,000).
• A flat penalty of €10,000 applies for failure to file any GloBE return on time, failure to comply with a Revenue notice to furnish particulars or produce documents, or deliberately assisting in the submission of an incorrect return, account, statement or declaration.
• In penalty recovery proceedings, a certificate from a Revenue officer confirming non-receipt of a return or non-compliance with a notice is accepted as evidence unless the entity can prove otherwise.
• Transitional penalty relief applies for fiscal years beginning on or before 31 December 2026 and ending on or before 30 June 2028, provided the entity has taken reasonable care to comply with the GloBE rules.