New reporting obligations will be imposed on Irish regulated funds which invest in Irish real estate and related assets (so called Irish real estate funds or IREFs).
Under the new regulations, IREFs must provide the Irish Revenue Commissioners with financial statements and related materials. These must be filed by 30 January 2019, with respect to the financial year ending 31 December 2017. For financial periods ending on 31 December 2018, the statements must be filed by 30 July 2019.
The obligations are contained in a statutory instrument published on 21 September 2018. The filing must be made electronically and include the financial statements, the auditors report and notes to the financial statements. The Revenue Commissioners have ancillary powers to inspect additional records and make enquiries to establish whether the information provided is correct.
Given the short timeframe for compliance, investment managers and directors should confirm that they are in a position to make the necessary filings. This measure is not unexpected, but does add to the compliance burden for those using Irish regulated funds to hold and manage Irish real estate.
These changes only impact Irish regulated funds which invest in Irish real estate related assets. Other regulated Irish funds are not affected.
These Regulations may be cited as the Investment Undertaking Electronic Account Filing Requirements Regulations 2018.