Ireland: New administrative requirements for section 110 companies

International Tax Review is part of Legal Benchmarking Limited, 4 Bouverie Street, London, EC4Y 8AX

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Ireland: New administrative requirements for section 110 companies

intl-updates-small.jpg
smith.jpg
galvin.jpg

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: www.revenue.ie.

Kevin Smith (kevin.smith@matheson.com) and Turlough Galvin (turlough.galvin@matheson.com)

Matheson

Tel: +353 1 232 2045 and +353 1 232 2232

Website: www.matheson.com

more across site & shared bottom lb ros

More from across our site

While pillar one is still alive, it will apply to a smaller group of companies, Brian Foley also told ITR
Tax teams that centralise and automate their pillar two data will have a much easier time during reporting season, says Hank Moonen, CEO of TaxModel
While GCCs drive efficiency for multinationals, they also present a host of TP risks that should be considered carefully
PwC Ireland has also called for simplifying Ireland’s tax code and a reduction in its capital gains tax in a pre-budget submission
Effective audit management requires more than documentation; it’s the way taxpayers engage that can shape audit direction, manage procedural ambiguity, and preserve options for appeal or litigation
American advisers are falling short of client expectations when it comes to providing value-added services, but remaining tight-lipped won’t make the problem go away
Awards
The Social Impact Awards unveil new categories to reflect a changing legal and social landscape
Australia's approach to tax policy has undergone significant shifts in recent years, reflecting global trends and unique domestic considerations. These developments merit close attention from tax professionals
The UK has temporarily dodged the 50% rate due to a trade deal signed with the US in May; in other news, Ryan acquired a Northern Irish tax firm
Following a $28 million funding round, Aibidia wants to ‘double down’ on the US market via partnerships with the ‘big four’, the Finnish TP tech provider’s CEO tells ITR
Gift this article