I am advised by the Revenue Commissioners that there is no requirement in Irish tax law for a company to claim or obtain authorisation of non-resident status from Revenue and that statistics on the number of Irish registered non-resident companies are not separately compiled. Accordingly, it is not possible to identify from Revenue records the number of Irish registered non-resident companies, how many of such companies have not declared any state of residence or how many companies are resident in a tax haven. A company that fails to deliver a statement of particulars under section 882 is liable to a penalty of €4,000, with provision for a further penalty of €60 for each day on which the failure continues after a court judgement has been obtained.
However, there is no specific fine applicable where a non-resident company fails, or is unable, to provide a country of residence in the statement of particulars to be provided under section 882 of the Taxes Consolidation Act 1997. The primary purpose of this provision is to ensure that newly incorporated companies coming within the charge to Irish corporation tax are registered with Revenue for tax purposes.
Non-resident companies that are liable to Irish corporation tax because they are carrying on a trade in the State through a branch or agency are not required to provide a country of residence in their annual corporation tax return.