Guidance on Pillar Two updated

Revenue has updated its guidance in two of its manuals on the operation and administration of Ireland’s Pillar Two legislation. The guidance materials in question are:

• Part 04A-01-02 – Global Minimum Level of Taxation for Multinational Enterprise Groups and Large-Scale Domestic Groups in the Union
• Part 04A-01-01 – Global Minimum Level of Taxation for Multinational Enterprise Groups and Large-Scale Domestic Groups in the Union - Administration

Finance Act 2024 provides that certain of the amendments to Part 4A TCA 1997 shall apply in respect of a fiscal year or an accounting period commencing on or after 31 December 2024. The guidance in Part 04A-01-02 has been updated to confirm that Revenue is prepared to accept the application of these provisions to a fiscal year or an accounting period commencing prior to 31 December 2024.

The administrative guidance contained in Part 04A-01-01 has been updated to outline how the Undertaxed Profit Rule (UTPR) and the Qualifying Domestic Top-Up Tax (QDTT) group recovery provisions are applied where a securitisation entity is part of a UTPR and a QDTT group.