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ARTICLE · 04 OCTOBER 2022

Ireland Signposts Pillar 2 Changes In Budget 2023

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On 27 September 2022, the Irish Minister for Finance presented Budget 2023 (the "Budget") which included a statement reaffirming Ireland's commitment to the OECD's proposed global minimum effective corporate tax rate ("Pillar Two").

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Tomás Bailey
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Shane Hogan
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On 27 September 2022, the Irish Minister for Finance presented Budget 2023 (the "Budget") which included a statement reaffirming Ireland's commitment to the OECD's proposed global minimum effective corporate tax rate ("Pillar Two").  Importantly, the Minister also signposted a number of amendments and ongoing work to better align Ireland's corporation tax system with the Pillar Two rules, which are currently expected to be implemented by 31 December 2023.

Proposed Amendments:

The following reformative measures were highlighted in the Budget in relation to the implementation of Pillar Two in Ireland:

  • Research and Development ("R&D") tax credit: The existing R&D tax credit will be amended to ensure that it is a qualifying refundable tax credit for Pillar Two and US foreign tax credit purposes.  A company will now have an option to request payment of the credit without offsetting it against other tax liabilities first.  In addition, the current limits on the

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