6 Notification obligations

(1) An ultimate parent entity, surrogate parent entity or EU designated entity shall, where it is resident for tax purposes in the State, not later than the last day of the fiscal year to which a country-by-country report relates, notify the Commissioners in writing that it is such an entity.

(2) Subject to paragraph (3), a domestic constituent entity shall, not later than the last day of the fiscal year to which a country-by-country report relates, notify the Commissioners in writing of the—

(a) identity,

(b) jurisdiction of tax residence, and

(c) type,

of the reporting entity.

(3) (a) Where there is more than one domestic constituent entity of the same MNE group, that MNE group may, where Regulation 3(1) does not apply, nominate one such domestic constituent entity for the purposes of paragraph (2).

(b) Where an ultimate parent entity, surrogate parent entity or EU designated entity of an MNE group makes a notification in accordance with paragraph (1) that entity may specify that such notification satisfies the notification requirements of paragraph (2) for each domestic constituent entity of that MNE group.

(4) Where paragraph (2)(c)(i) of Regulation 3 applies, a domestic constituent entity shall, not later than 12 months after the last day of the fiscal year to which an equivalent country-by-country report relates, notify the Commissioners in writing that its ultimate parent entity has refused to provide it with all information required to enable the domestic constituent entity to prepare and provide a country-by-country report.

(5) In paragraph (2), “type” means an ultimate parent entity, a surrogate parent entity, an EU designated entity or a domestic constituent entity.