Pillar Two – Global Minimum Taxation & Ireland

Key takeaways

• The Irish Pillar Two rules apply to in-scope entities for accounting periods commencing on or after 31 December 2023. Following the GloBE Rules and the EU's Minimum Tax Directive, the rules introduce a minimum effective tax rate ("ETR") of 15% for large multinational enterprises (MNEs) or large-scale domestic groups with a global turnover of €750 million or more in two of the previous four fiscal years. The Irish rules can also apply to standalone entities (i.e. entities that are not part of a consolidated group) above the revenue threshold (subject to any applicable exemptions).

• The Irish Pillar Two rules introduce a domestic top-up tax regime which is designed to obtain "qualified" status and to be eligible for the QDMTT Safe Harbour.