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 & bottom lb ros

More from across our site

Baker McKenzie’s survey of 600 corporate counsel also found that global employee mobility issues were a key driver of tax controversy
Ken Kies has been named as assistant secretary for tax policy; in other news, Baker McKenzie has boosted its US tax practice with a double hire
The increasing sophistication of India’s taxation system has led to complexity across tax treaty benefits, permanent establishments, transfer pricing and more, say Sanjay Sanghvi and Ujjval Gangwal of Khaitan & Co
Multinationals will continue to shift profits out of Slovakia to EU member states despite pillar two’s implementation, according to the report
The firm’s final report outlined new mandatory staff training designed to enhance ethical conduct; meanwhile former PwC Australia partner Wayne Plummer has been cleared of wrongdoing
Goods and services key to Africa’s tax revenue; electronic exemptions come to Europe; UK private school VAT challenge reaches High Court
The private client practice joining Withers comprises eight lawyers, three paralegals and additional staff members
Overall tax revenues grew by over 10% in 2024 when discounting the 'distorted' Apple payout, the Irish government said
Skatteforvaltningen is being represented by international law firm Hughes Hubbard in its efforts to reclaim monies related to an alleged long-running international fraud
SafeSend automates the ‘last mile’ of the tax return, according to Thomson Reuters; in other news, law firm White & Case has expanded its global tax practice in the US
Gift this article