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Ireland: New administrative requirements for section 110 companies

26 April 2017

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Kevin Smith Turlough Galvin

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 1997 (TCA).

Section 110 of the TCA sets out Ireland's tax treatment of securitisation companies.

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 either:

  • 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 TCA.

Both forms are available on Revenue's website here:

Kevin Smith ( and Turlough Galvin (
Tel: +353 1 232 2045 and +353 1 232 2232

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