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ARTICLE · 02 AUGUST 2024

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Pillar Two Update - Securitisation Entities

McCann FitzGerald LLP
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McCann FitzGerald LLP

McCann FitzGerald LLP

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On 17 June last, the Organisation for Economic Co-operation and Development ("OECD") released further Administrative Guidance on the ‘Pillar Two' Global Anti-Base Erosion ("GloBE") Rules (the "Guidance").

IrelandTax
Eleanor MacDonagh
Eleanor MacDonagh
Deirdre Barnicle
Deirdre Barnicle

Introduction

On 17 June last, the Organisation for Economic Co-operation and Development ("OECD") released further Administrative Guidance on the 'Pillar Two' Global Anti-Base Erosion ("GloBE") Rules (the "Guidance").

As anticipated, among other matters addressed therein, the Guidance specifically considers Securitisation Entities (as defined below).

While many Securitisation Entities will not be directly impacted by the OECD GloBE rules (as a result of not being a constituent entity of a group with annual consolidated revenue of at least EUR 750 million, or a standalone entity with revenue of at least EUR 750 million), for those Securitisation Entities that are directly impacted, the Guidance is of particular significance.

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