Jonathan Sheehan
Managing Partner
Ireland
Key takeaways
Pillar Two is one element of an October 2021 agreement by 137 jurisdictions (including Ireland) in the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting, the overall aim of which is to reform the international tax framework as it applies to large corporate groups.
The Pillar Two rules, known as the Global Anti-Base Erosion Rules (GloBE Rules), are designed to ensure that MNEs pay a minimum level of tax on the income arising in each jurisdiction in which they operate. The rules seek to impose a top-up tax on profits arising in a jurisdiction whenever the ETR, determined on a jurisdictional basis, is below the minimum rate of 15%.
Ireland transposed Council Directive 2022/25/23 (the Minimum Tax Directive) into Irish law in Finance (No.2) Act 2023. The Irish Pillar Two rules are in force for in-scope entities for accounting periods commencing on or after 31 December 2023.
For more information on this, please contact any member of Walkers' Tax Group in Ireland or your usual Walkers' contact. Walkers has a team of dedicated professionals in Ireland and across our other offices where legislation implementing elements of Pillar Two is at various stages of implementation such as Bermuda, Jersey and Guernsey.
Authors
Managing Partner/Ireland
Tax Consultant/Ireland
Associate/Ireland
Key contacts
Managing Partner
Ireland
Tax Consultant
Ireland