Revenue has updated the Tax and Duty Manual which contains an overview of the administration of Pillar Two, the global minimum level of taxation for multinational enterprise groups and large-scale domestic groups.
The updated guidance reflects amendments to Part 4A TCA 1997 contained in Finance Act 2024 as follows:
- clarification of the meaning of a “designated filing entity” (Section 2.3),
- clarification that the specified return date of an entity shall be 30 June 2026 where the specified return date of that entity, or group, would otherwise arise before 30 June 2026 (Section 2.8),
- clarification that the notification date of an entity or group shall be 31 December 2025 where a registration notification date of that entity, or group, arises before 31 December 2025 (Section 3),
- clarification that GloBE taxes fall due and payable on 30 June 2026 where the specified return date would otherwise arise before 30 June 2026 (Section 13),
- Table 1 - five year elections provides for the allocation of deferred tax expense election (Section 19.1), and
- Table 2 - annual elections provides for the simplified calculations safe harbour election (Section 19.2).
Revenue has also updated the Tax and Duty Manual which provides guidance in relation to the operation of the Pillar Two rules as follows:
- widely held investment funds, master-feeder investment funds and umbrella fund/sub fund structures (Section 5.1),
- the interaction of tax residency and location of a constituent entity in certain circumstances (Section 5.4),
- the interaction of Part 35A TCA 1997 and Section 111P(4) TCA 1997 (Section 7.2).
- refundable and marketable transferable tax credits and intra-group financing arrangements (Section 7.2), and
- identifying the "ownership holder" referred to in Section 111AQ(1) TCA 1997 (Section 11.1).
Revenue has advised that this manual will be further updated in due course to reflect the amendments made to Part 4A by Finance Act 2024.
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