Taxes Consolidation Act 1997 section 172L

Reporting of distributions made under stapled stock arrangements

Section 172L requires Irish resident companies to report distributions made by associated non-resident companies under stapled stock arrangements.

• A distribution is treated as made under a stapled stock arrangement where a person has chosen to receive distributions from a non-resident company instead of from an Irish resident company, and that choice has not been revoked.
• The resident company must file a return with Revenue within 14 days of the end of each month in which such distributions were made, detailing the recipients, dates, and amounts.
• Returns must generally be filed electronically in a format approved by Revenue, accompanied by a declaration that the return is correct and complete.
• Where Revenue is satisfied that a company lacks the facilities for electronic filing, a written return in a prescribed form may be submitted instead.