Taxes Consolidation Act 1997 section 111AAH

Obligation to register

Section 111AAH obliges entities within scope of GloBE top-up taxes to register with Revenue, sets out the information required in the registration notice, and imposes penalties for non-compliance.

• Entities subject to IIR top-up tax, UTPR top-up tax or QDTT must notify Revenue within 12 months of the end of the first fiscal year they come within scope, with a backstop registration date of 31 December 2025 for entities whose obligation arose before that date.
• The registration notice must include the entity's name, TIN, the taxes it is registering for, details of the ultimate parent entity and designated filing or local entities where applicable, and any elections to form QDTT or UTPR groups.
• Any change to the registered information must be notified to Revenue within 12 months of the end of the fiscal year in which the change occurred, and an entity that ceases to be within scope must notify Revenue of its cessation within the same timeframe.
• Failure to register, update registration details or notify cessation carries a penalty of €10,000 per breach.