This article is for non‑resident beneficial owners, company directors, secretaries and compliance professionals who need to file Irish Register of Beneficial Ownership (RBO) submissions, especially when they lack a PPS number.
You will learn why the PPS is required, how to obtain an Identified Person Number (IPN) via the VIF form, and the step‑by‑step process for completing an RBO filing, plus how to avoid common pitfalls and penalties.
Key Takeaways
Non‑resident beneficial owners must obtain an Identified Person Number (IPN) by completing Form VIF, as they typically lack a PPS number required for RBO filing.
The RBO requires filing within five months of incorporation and any changes within 14 days, with non‑compliance attracting fines up to €5,000 or €500,000 and possible imprisonment.
The PPS number is used to verify identity against the Department of Social Protection’s database, making it a critical field that causes rejections if mismatched or absent.
Obtaining an IPN involves downloading Form VIF, making a statutory declaration, having it notarised or witnessed, uploading it to the CRO’s CORE portal, and then using the issued IPN for the RBO submission.
Paul Burke is a qualified ACA and CTA tax accountant in Ireland.He trained at Forvis Mazars in Galway, gaining experience in various tax heads including Income Tax, Corporation Tax, VAT, Payroll and Tax Advisory.He is now a Tax Consultant in a local tax firm.
What is an IPN and why is it needed for non‑resident beneficial owners?
An Identified Person Number (IPN) is the alternative identifier used by non‑resident beneficial owners who do not have a Personal Public Service (PPS) number. The IPN is issued after completing Form VIF and allows the owner’s details to be validated by the RBO, enabling a compliant filing.
How can a non‑resident obtain an IPN through Form VIF?
To obtain an IPN, download Form VIF from the CRO website, fill in personal details, make a statutory declaration, and have the form verified by a notary public (outside Ireland) or a Commissioner for Oaths (in Ireland). Upload the signed form to the CRO CORE portal; once approved, the CRO issues the IPN.
What penalties apply if the RBO filing is not completed or is inaccurate?
Failure to file the RBO or to provide accurate information can lead to a Class A fine of up to €5,000 or imprisonment of up to twelve months on summary conviction, and up to €500,000 or twelve months imprisonment on indictment. Directors, managers and company secretaries may also face personal liability.
What information must be provided for each beneficial owner?
Each beneficial owner must provide full legal name, date of birth, PPS number or IPN, nationality, residential address, percentage of shares or voting rights held, nature and extent of control, and the date they became a beneficial owner. All details must match the records held by the Department of Social Protection or the CRO.
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