Pillar Two Feedback Statement



In October 2021, Ireland along with 130 other counties signed up to an historic agreement to reform the international tax framework for large corporate groups. Building on the original BEPS project, the agreement contains a Two Pillar solution to address the tax challenges arising from digitalisation and globalization. In the EU, these rules are contained within the Pillar Two Directive, which requires EU Member States to introduce a global minimum effective tax rate of 15% for corporate groups with annual turnover of at least €750 million.


Feedback Statement

On 31 March 2023, the Department of Finance published a feedback statement on implementing the Pillar Two rules in Ireland. Interested stakeholders were invited to submit their views on several aspects of the rules by 8 May 2023. The feedback statement also provides insight into some of Ireland’s policy choices in introducing the rules.

The feedback statement seeks input from stakeholders under three main headings:

  1. Proposed legislative approach
  2. Qualifying domestic top-up tax
  3. Administration


Proposed legislative approach

The feedback statement confirms that the EU Directive will provide the primary basis for the transposition of the minimum tax rules in Ireland.

The feedback statement includes possible draft legislative approaches to the Directive, and asks stakeholders to comment on what references should be made to the OECD model rules, commentary and administrative guidance in implementing legislation.


Qualifying domestic top-up tax (QDTT)

Under the Directive, EU Member States may elect to apply a top-up tax. This would mean that the additional tax would be collected in Ireland, rather than in another jurisdiction. The feedback statement confirms that, as Ireland’s 12.5% trading rate of Corporation Tax is below the agreed 15% minimum effective rate, Ireland intends to introduce a QDTT as part of the Pillar Two implementation process, and seeks feedback on its implementation.



The introduction of the new minimum tax will give rise to new pay and file obligations for taxpayers. The feedback statement suggests that administration of Pillar Two should be kept separate to Ireland’s existing Corporation Tax regime, and asks stakeholders to comment on a number of administrative issues, including:

  • Registration and de-registration;
  • Filing of GloBE information returns and notifications;
  • Filing of domestic returns / self-assessment;
  • Payments;
  • Record keeping;
  • Other administration provisions (such as appeals and assessment); and
  • Group filings / payments.



It is intended that the legislation will be transposed into Irish law via the Autumn 2023 Finance Bill, and will take effect from 1 January 2024.

Please get in touch with us if you have any queries on how Pillar Two may impact your business.

Find out how our Financial Services Tax team can help you here.