Taxes Consolidation Act 1997 section 917B

Return by settlor in relation to non-resident trustees

Section 917B requires a settlor who is domiciled and resident (or ordinarily resident) in the State to notify Revenue when creating certain offshore or treaty-protected settlements.

  • The section applies where a settlement is created on or after 11 February 1999 and the trustees are either non-resident or, although Irish resident, are treated as resident in another territory under a double taxation agreement
  • A settlor who is domiciled in the State and is either resident or ordinarily resident in the State must deliver a statement to the appropriate inspector within three months of the date the settlement is created
  • The statement must specify the date the settlement was created, the settlor's name and address, and the names and addresses of the current trustees at the time of delivery
  • A penalty of €4,000 applies for each failure to deliver the required statement or to include all of the required details in it

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