Ireland: Updated Pillar Two guidance

Application of the Irish minimum taxation rules

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August 28, 2025

Irish Revenue on July 31, 2025, published updated guidance on the application of the Irish minimum taxation rules (Pillar Two). The guidance includes changes to several sections, including:

  • Treatment of insurance investment entities
  • Treatment of intra-group financing arrangements in the context of the determination of global anti-base erosion (GloBE) income
  • Treatment of post-filing adjustments and tax rate changes in the context of the determination of covered taxes (including the treatment of tax expense relating to pre-transition fiscal years)
  • Application of the transitional country-by-country (CbC) reporting safe harbour, as it relates to the calculation of simplified covered taxes relating to pre-transition fiscal years
  • Treatment of constituent entities joining and leaving multinational enterprise (MNE) groups or large-scale domestic groups, as it relates to mergers
  • Treatment of joint ventures, as it relates to interactions with the undertaxed profits rule (UTPR), scope of application, unaligned accounting periods and the domestic top-up tax

Read an August 2025 report prepared by KPMG’s EU Tax Centre

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