Revenue eBrief No. 136/24

15 May 2024

Implementation of Council Directive (EU) 2022/2523 of 15 December 2022 on Ensuring a Global Minimum Level of Taxation for Multinational Enterprise Groups and Large-Scale Domestic Groups in the Union

Section 94 of Finance (No.2) Act 2023, by inserting a new Part 4A of the Taxes Consolidation Act (TCA) 1997, implemented the Pillar Two minimum effective tax rate for large groups and companies by transposing the EU Minimum Tax Directive (Council Directive (EU) 2022/2523 of 14 December 2022 on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the Union) (the ‘EU Minimum Tax Directive’) into Irish law.

Tax and Duty Manual – Part 4a-01-02 contains an overview of the main Pillar Two charging rules along with a detailed correlation table which cross references the legislation contained in 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.

Revenue is engaging with the Tax Administration Liaison Committee (TALC), specifically the TALC BEPS sub-committee, in respect of areas of guidance on the Pillar Two rules. This Tax and Duty manual will be expanded in due course to include further guidance on the Pillar Two rules contained in Part 4A of the TCA 1997.