Revenue eBrief No. 213/24
08 August 2024
Global Minimum Level of Taxation for Multinational Enterprise Groups and Large-Scale Domestic Groups in the Union - Administration
Tax and Duty Manual (TDM) Part 04A-01-01 is a new manual which contains an overview of the Administration of Pillar Two.
In addition to this Administration of Pillar Two TDM, the recently published Part 04A-01-02 has been updated. TDM 04A-01-02 now contains guidance on the operation of the Pillar Two rules along with the detailed correlation table which cross references the legislation contained within Part 4A of the TCA 1997 with:
- the relevant article of the EU Minimum Tax Directive,
- the relevant article of the OECD Model Rules,
- OECD Commentary, where relevant, and
- OECD Administrative Guidance, where relevant.