The updated guidance on OECD Pillar Two global minimum tax clarifies rules for insurance investment entities, intra-group financing adjustments, pre-transition tax changes, and transitional CbC reporting safe harbor rules.
The Irish Revenue Commissioners issued Revenue eBrief No. 150/25 on 31 July 2025, updating guidance on the OECD Pillar Two global minimum tax for MNEs and large domestic groups.
The updates clarify definitions of insurance investment entities, adjustments to determine qualifying income or loss, as it relates to intra-group financing arrangements; Post-filing adjustments and tax rate change, as it relates to covered taxes relating to pre-transition fiscal years and the application of outcomes arising from mutual agreement procedures; and Transitional CbCR safe harbour, as it relates to the calculation of simplified covered taxes relating to pre-transition fiscal years.
Additionally, the guidance provides updates on constituent entities joining or leaving MNE or large domestic groups, addressing mergers, joint ventures, UTPR interactions, application scope, unaligned accounting periods, and domestic top-up tax.
