Taxes Consolidation Act 1997 section 111AAI

Top-up tax information return

Section 111AAI sets out the obligation on constituent entities to prepare and deliver a top-up tax information return to the Revenue Commissioners, including the required content of the return, the circumstances in which an entity may be relieved of the filing obligation, and the notification requirements where a return is filed in another jurisdiction.

• A constituent entity located in the State must prepare and deliver a correct and complete top-up tax information return to Revenue on or before the specified return date, following the standardised GloBE Information Return template.
• The filing obligation may be satisfied where an ultimate parent entity or designated filing entity files the return in another jurisdiction that has a qualifying competent authority agreement with the State, but the constituent entity must still submit a notification of filer to Revenue.
• The return must include entity identification details, corporate structure information, data necessary to calculate effective tax rates and top-up taxes for each jurisdiction, records of elections made or withdrawn, and any other information Revenue may reasonably require.
• Amendments to a filed return are permitted only to correct errors or mistakes, or to comply with other provisions of Part 4A, and the Revenue Commissioners are authorised to share information from the return with competent authorities in other jurisdictions under a qualifying competent authority agreement.