Ireland: Consultation closed on the implementation of the Pillar Two Minimum Tax Rate

On 22 July 2022, the Irish government closed a consultation on the implementation of the OECD/G20 Pillar Two Minimum Tax Rate agreement. The consultation started on 26 May 2022. The Pillar Two agreement attempts to tackle the growing issues of globalization and digitisation by imposing a 15% minimum tax on profits from multinational companies with revenues over EUR 750 million. The purpose of the consultation is to comment on how those rules can be implemented in the Irish domestic context. The government outlined 25 questions for the stakeholders. In general, the Irish government wishes to know whether there are certain domestic tax laws that would need particular attention or reform when implementing Pillar Two, specifically when taxing US multinational corporations. In particular, the questions regard the computation of GloBE income or loss provisions, the computation of adjusted covered tax provisions, the interaction of tax credits, the computation of the effective tax rate and whether a qualified domestic top-up tax should be implemented.