Taxes Consolidation Act 1997 section 891H

Country-by-country reporting

Section 891H requires Irish-resident parent companies of large multinational enterprise (MNE) groups to file an annual country-by-country (CbC) report with Revenue, breaking down revenue, profits, taxes, and other economic indicators for each jurisdiction in which the group operates.

• An Irish-resident ultimate parent entity of an MNE group with consolidated revenue of €750 million or more must file a CbC report within 12 months of the end of its fiscal year, for fiscal years beginning on or after 1 January 2016.
• The report must detail, for each jurisdiction, the group's revenue, profit before tax, taxes paid and accrued, stated capital, accumulated earnings, employee numbers, and tangible assets, together with the identity and business activities of each constituent entity.
• Revenue may make regulations requiring entities other than the parent to file CbC reports, specifying filing formats, deadlines, notification obligations, confidentiality provisions, and other operational matters.
• Finance Act 2025 introduces specific rules for applying the €750 million threshold where the preceding accounting period is shorter than 12 months, where a group has recently separated from a larger group, and where extraordinary investment income and gains appear in the consolidated financial statements.