On 18 December 2023, Ireland enacted the Finance Act (No. 2) 2023 (Act No. 39 of 2023), which contains provisions for the Pillar 2 global minimum tax in line with Council Directive (EU) 2022/2523 of 14 December 2022.
In addition to the Pillar 2 global minimum tax, this law also includes the Pillar 2 income inclusion rule (IIR) and the undertaxed payment/profit rule (UTPR) to ensure a minimum corporate tax of 15% for large multinational (MNE) groups with annual consolidated revenue of at least EUR 750 million in at least two of the preceding four fiscal years. The rules apply to all domestic and international groups with a parent company or subsidiary in an EU member state. The bill also proposes implementing a qualified domestic minimum top-up tax (QDMTT) for members of in-scope groups and certain safe harbors.
The IIR and QDMTT apply for financial periods beginning on or after 31 December 2023, while the UTPR generally applies for financial periods beginning on or after 31 December 2024.
On 31 March 2023, the Irish Department of Finance published a public consultation document on the transposition of the OECD Pillar Two global minimum tax rules. The consultation period ended on 8 May 2023.
