On 27 July 2023, the Irish Government released second feedback statement on the transposition of the OECD Pillar Two global minimum tax rules in line with EU Council Directive 2022/2523 of 14 December 2022. The consultation period will run to close of business on Monday 21 August 2023.
This Feedback Statement builds on the March Feedback Statement and on the public consultation carried out last year. The draft legislative approaches in the below sections contain cross references to the draft legislative approach contained in the March Feedback Statement and therefore should be read in conjunction with the March Feedback Statement.
Interested stakeholders are therefore invited to:
- Give views on the specific questions set out below, noting that there is no requirement to answer every question.
- Provide numerical examples, where relevant, to illustrate your points.
- Provide details of alternative approaches that you feel might be beneficial (including minor suggestions).
- Where appropriate, estimate any Exchequer cost/yield of your preferred option.
- Provide details of relevant issues not covered in this Feedback Statement.
The contents of this Feedback Statement are as follows:
Section 2: Transitional CbCR Safe Harbour
Section 3: Transitional UTPR Safe Harbour
Section 4: QDTT/QDMTT and Safe Harbour status
Section 5: Pillar Two Elections
Section 6: OECD Model Rules, Commentary, Administrative Guidance
Section 7: Administration and Globe Information Return (GIR)
