Taxes Consolidation Act 1997 section 111AAX

Surcharge for late return

Section 111AAX imposes a late filing surcharge on entities that fail to deliver a GloBE return by the specified return date, with the surcharge rate depending on the length of the delay.

• A surcharge of 5% applies where the GloBE return is delivered up to 2 months late, capped at €50,000; a surcharge of 10% applies where it is more than 2 months late, capped at €200,000.
• Interest is charged on any surcharge as if it were GloBE tax, and the surcharge and interest are recoverable in the same manner as GloBE tax.
• A return filed on time but containing deliberate or careless errors is deemed late unless corrected by the due date; a return with an innocent error is deemed late unless corrected without unreasonable delay once the error comes to the entity's notice.
• Where Revenue require additional evidence or a further return and the entity fails to comply within the period specified in the notice, the original return is deemed to have been filed late.