Irish Revenue has released eBrief No. 213/24, which provides new guidance on administering the Pillar Two global minimum tax, along with updated information on the implementation of the Pillar Two rules, on 8 August 2024.
The Tax and Duty Manual (TDM) Part 04A-01-01 is a new manual which contains an overview of the Administration of Pillar Two. In addition to this Administration of Pillar Two TDM, the recently published Part 04A-01-02 has been updated.
TDM 04A-01-02 now contains guidance on the operation of the Pillar Two rules along with the detailed correlation table, which cross references the legislation contained within Part 4A of the TCA 1997 with:
- The relevant article of the EU Minimum Tax Directive;
- The relevant article of the OECD Model Rules;
- OECD Commentary, where relevant; and
- OECD Administrative Guidance, where relevant.
Irish Revenue also released a new Tax and Duty Manual – Global Minimum Level of Taxation for Multinational Enterprise Groups and Large-Scale Domestic Groups in the Union – Administration, which contains detailed guidance regarding the administrative requirements under Pillar Two minimum tax.
The new guidance covers essential topics such as registration procedures for Pillar Two requirements, top-up tax information returns, and compliance provisions. It also addresses the income inclusion rule (IIR), undertaxed payments rule (UTPR), and related group provisions, along with aspects of GloBE taxes and transitional reporting.
