Taxes Consolidation Act 1997 section 111AAP

QDTT group recovery

Section 111AAP sets out the process by which Revenue can recover unpaid domestic top-up tax from other members of a QDTT group where the QDTT group filer has failed to pay within 12 months of the due date.

• Where a QDTT group filer fails to pay domestic top-up tax within 12 months of the payment deadline, an authorised Revenue officer can issue a written notice to another member of the QDTT group demanding payment of the outstanding amount (including any related interest, surcharges, or penalties) within 30 days.
• The authorised officer has a window beginning 12 months after the due date and ending 4 years after the due date in which to serve the notice on a relevant QDTT member.
• If the member served with the notice fails to pay the full amount, the officer can revoke that notice and issue a new one to a different group member, repeating this process until the full amount is collected; any member who pays can recover the amount from the QDTT group filer.
• A notice cannot be served on a QDTT member that is a securitisation entity if there is at least one other relevant QDTT member in the group (other than the group filer) that is not a securitisation entity.