Revenue eBrief No. 139/22

04 July 2022

Securitisation Regulation (Regulation (EU) 2021/557 of the European Parliament and of the Council of 31 March 2021); Notification of investment (‘NOI’)

Regulation (EU) 2021/557 of the European Parliament and of the Council of 31 March 2021 entered into force on 9 April 2021.

It provides that an investor in a Securitisation Special Purpose Entity (“SSPE”), established after 9 April 2021, in a jurisdiction listed in Annex II of the Council of the European Union’s list of non-cooperative jurisdictions for the reason of operating a harmful tax regime, must notify the tax authority in the Member State in which the investor is tax resident.

Tax and Duty Manual Part 38-03-30 provides guidance in relation to an Irish resident investor who is required to submit a Notification of Investment to Revenue.