Revenue eBrief No. 22/17

24 February 2017

Securitisation: Notification of "Qualifying Company" Section 110 Taxes Consolidation Act, 1997.

Section 110 TCA 1997 provides for a tax regime for certain special purpose companies. In order to be taxed under the provisions of section 110 TCA 1997 a company must, among other conditions, notify an "authorised officer" of the Revenue Commissioners that it is or intends to be a "qualifying company" to which paragraphs (a) to (e) of the definition of a "qualifying company" contained in section 110(1) TCA 1997 apply.

From 1 January 2017 additional information must be provided to Revenue as part of that notification (paragraph (f) of the definition of "qualifying company" in section 110(1) TCA 1997 refers). Form S.110 (Notification of qualifying company for the purposes of section 110 TCA 1997) and Form S.110W (Withdrawal of notification that a company is a qualifying company for the purposes of section 110 TCA 1997) are now available for completion.

Please refer to Tax and Duty Manual Part 04-09-03 for more details about when these two forms must be returned to the authorised officer.