Pillar Two guidance published

Following the introduction of the EU Minimum Taxation Directive (“Pillar Two") by Finance (No. 2) Act 2023, Revenue has now published its first detailed guidance on the application of the rules. The guidance is contained in TDM Part 4a-01-02 should be read in conjunction with Part 4A TCA 1997. 

The guidance provides an overview of the main Pillar Two charging rules. It also contains a detailed correlation table which cross references the legislation contained in Part 4A TCA 1997 with: 

• The relevant article of the EU Minimum Tax Directive 

• The relevant article of the OECD Model Rules 

• OECD Commentary, where relevant 

• OECD Administrative Guidance, where relevant. 

The guidance has been drafted by Revenue following robust and ongoing engagement with stakeholders (including the Institute under the auspices of the CCAB-I) via the Tax Administration Liaison Committee (TALC), specifically the TALC BEPS sub-committee. The guidance will likely be subject to ongoing development as Revenue and practitioners began working through the detailed calculations required under the Pillar Two rules.