Taxes Consolidation Act 1997 section 111AAF

Interpretation (Chapter 10)

Section 111AAF defines the key terms and administrative requirements used throughout the GloBE (Global Anti-Base Erosion) tax provisions in Chapter 10 of Part 4A, covering the Income Inclusion Rule (IIR) top-up tax, the Undertaxed Profits Rule (UTPR) top-up tax, and the domestic top-up tax (QDTT).

  • The section defines core terms including 'GloBE tax' (covering IIR top-up tax, UTPR top-up tax, and domestic top-up tax), 'GloBE return' (covering the corresponding returns for each), 'assessment' (including both self-assessment and Revenue assessment), and 'qualifying entity', 'relevant parent entity' and 'relevant UTPR entity' as the entities liable to each type of top-up tax.
  • The 'specified return date' is the last day of the 15-month period following the end of the fiscal year, extended to 18 months where the fiscal year is a transition year (the first year an entity comes within scope), and where a return date would otherwise fall before 30 June 2026, the deadline is instead 30 June 2026.
  • All notifications, notices, returns and other documents required under this Part must be delivered electronically through the Revenue Commissioners' designated systems, with the provisions of Chapter 6 of Part 38 applying to electronic delivery.
  • For the purposes of this Chapter, the term 'entity' includes a permanent establishment, and 'fiscal year' includes the accounting period of an entity to which section 111AAB(1)(c) applies.

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