Ireland: New administrative requirements for section 110 companies

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

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

As demand for complex, cross-border private client counsel spikes, Patrick McCormick sees opportunity in starting from scratch
As part of an exclusive global alliance, KPMG will become one of Anthropic’s ‘preferred consultants’ for private equity
In the second part of this series, the focus shifts to how taxpayers can manage ongoing risks across the lifecycle of cross-border structures
Jurisdictions have moved to ensure that multinationals are not punished for late GIR filings due to a lack of available filing portals or exchange relationships
HMRC’s push for unified tax adviser registration won’t prevent every instance of improper conduct, but it is good for taxpayers and the UK’s reputation
Elsewhere, the UAE’s tax office has issued an update on registration penalties and two firms have been busy making lateral hires
The case sits within a context of Brazil signalling that it is replacing informal discretion and ambiguity with structures that reward analytical rigour, one expert tells ITR
Jeff Soar lifts the lid on WTS UK’s ambitious recruitment plans, the firm's positioning against the big four, and why tax is the perfect profession for AI
The move reinforces Milan’s role as a key European hub for international business, the firm said
Australia’s government has also announced that it will implement the pillar two side-by-side agreement
Gift this article