On May 4, 2018 the Irish Revenue issued Revenue eBrief No. 82/18 to announce that it created a new Tax and Duty Manual on Country-by-Country Reporting (PART 38-03-21). According to the Irish Revenue the manual has been created to address some frequently asked questions on the interpretation of legislation and regulations which implement Country-by-Country Reporting in Ireland.

 

The Irish Rvenue furthermore states that the manual replaces the document "Country-by-Country Reporting - some Frequently Asked Questions (FAQs)" which was previously available on the website of the Irish Revenue.

 

The manual discusses a.o. the following questions and subjects:

·   What is CbC Reporting and who does it apply to?

·   What is the OECD/G20 guidance on CbC Reporting?

·   What is the Irish legislation governing CbC Reporting?

·   Can the OECD guidance on CbC Reporting be used to interpret the Irish CbC Reporting Legislation?

·   How should terms contained in the Irish CbC Reporting Legislation and this manual be interpreted?

·   When did the CbC Reporting requirements come into effect in Ireland?

·   Who is required to file a CbC Report in Ireland?

·   When can a surrogate parent be appointed?

·   What are the obligations of an Irish tax resident constituent entity which has been appointed as a surrogate parent entity?

·   What information should a CbC Report contain?

·   What is the secondary reporting mechanism?

·   When does the secondary reporting mechanism apply in Ireland?

·   What are the requirements under the secondary reporting mechanism in Ireland?

·   What is an “Equivalent CbC Report” and what information should it contain?

·   Will the secondary reporting mechanism apply if an ultimate parent entity of an MNE Group files a CbC Report on a voluntary basis in its country of residence in respect of the 2016 fiscal year?

·   What is an EU designated entity and what are its obligations?

·   Is there any specific guidance on how to complete the CbC Report / Equivalent CbC Report?

·   What sources of data should be used to complete the CbC Report / Equivalent CbC Report?

·   Will Revenue seek to reconcile the CbC Report / Equivalent CbC Report to the consolidated accounts of an MNE Group?

·   How should the CbC Reporting rules be applied to investment funds?

·   How should the CbC Report / Equivalent CbC Report be filed?

·   The XML Schema User Guide states that a tax administration may issue guidance for the domestic reporting of CbC Reports. Is there any Irish Revenue guidance that should be followed for any elements within the CbC XML Schema?

·   Are there any character restrictions or combination of characters which should not be included in a CbC Report / Equivalent CbC Report?

·   Is it possible to amend or delete a CbC Report / Equivalent CbC Report after it has been submitted?

·   What character encoding should I use when compiling my CbC XML file?

·   When must a CbC Report / Equivalent CbC Report be filed with Revenue?

·   Short/long accounting periods

·   What happens if the ultimate parent entity of an MNE Group changes during a fiscal year?

·   What penalties apply for the non-filing of a CbC Report / Equivalent CbC Report or when the CbC Report / Equivalent CbC Report is incorrect or incomplete?

·   What notifications are required for CbC Reporting purposes in Ireland?

·   What is the deadline for making CbC Reporting notifications to Revenue?

·   How should CbC Reporting notifications be made to Revenue?

·   Is it possible to amend, replace or delete a CbC Reporting notification after it has been submitted?

·   How will Revenue obtain CbC Reports for Irish subsidiaries / permanent establishments of an MNE Group where the reporting entity is not tax resident in Ireland?

·   Will Revenue exchange CbC Reports filed in Ireland with other tax authorities?

·   What conditions must be satisfied before Revenue automatically exchanges CbC Reports with other tax jurisdictions?

·   Will Equivalent CbC Reports be exchanged with other tax authorities?

·   How will Revenue safeguard the confidentiality of information provided on CbC Reports / Equivalent CbC Reports?

·   What will the information provided on a CbC Report / Equivalent CbC Report be used for?

·   Who can I contact if I have a query relating to CbC Reporting?

 

Click here to be forwarded to the Tax and Duty Manual on Country-by-Country Reporting (PART 38-03-21) as available on the website of the Irish Revenue.

 

 

Copyright – internationaltaxplaza.info

 

 

Stay informed: Subscribe to International Tax Plaza’s Newsletter! It’s completely FREE OF CHARGE!

 

and

 

Follow International Tax Plaza on Twitter (@IntTaxPlaza)

 

 

 

Submit to FacebookSubmit to Google PlusSubmit to StumbleuponSubmit to TwitterSubmit to LinkedIn
INTERESTING ARTICLES