Ireland Tax Agency Updates Guidance on Pillar 2 Global Minimum Taxation

The Irish Revenue Commissioners Jan. 8 issued Revenue eBrief No. 010/26, updating guidance on global minimum taxation of multinational enterprise (MNE) and large-scale domestic groups under OECD Pillar Two. Topics covered include: 1) the undertaxed profits rule (UTPR) allocation key, with respect to measuring the number of employees and tangible asset net book value; 2) post-filing adjustments excluding calculation of the effective tax rate (ETR) and top-up tax, in certain cases of reductions in covered taxes in a constituent entity’s financial accounts related to pre-transition fiscal years; 3) the transitional country-by-country (CbC) reporting safe harbor, with respect to changes in ...