The Irish Revenue Commissioners (Revenue) have updated the
section 110 form (Form S110) that must be filed by companies
that qualify under section 110 of the Taxes Consolidation Act
Section 110 of the TCA sets out Ireland's tax treatment of
New Form S110
The new Form S110 is more detailed than the pre-existing
form and requires companies to include information about the
type of assets to be acquired, how the company is funded and
any transactions with related parties.
Companies that fail to file a Form S110 cannot avail of the
tax treatment applicable under section 110 of the TCA.
In order to qualify for the treatment available under
section 110 of the TCA, Form S110 must be filed no later than
eight weeks from the date the company first acquires qualifying
assets. If information required is not available at the time
the form is filed, the company is under an obligation to update
Revenue when it becomes available.
Withdrawing from section 110
Revenue have also formalised the process for companies that
previously qualified under section 110 of the TCA and
- No longer wish to be treated as qualifying
companies under section 110 of the TCA; or
- No longer satisfy all of the conditions
that must be met under section 110 of the TCA.
Those companies should file Form S110W, including the date
from which the company ceased to be (or wishes to cease to be)
treated as a qualifying company under section 110 of the
Both forms are available on Revenue's website here: www.revenue.ie.
Kevin Smith (firstname.lastname@example.org)
and Turlough Galvin (email@example.com)
Tel: +353 1 232 2045 and +353 1 232 2232