DAC9/GIR
Overview
Pillar Two requires Multinational Enterprises (MNEs) and large-scale domestic groups to pay a minimum of 15% tax on profits in each jurisdiction it operates.
MNEs within scope are those with consolidated annual revenues of €750 million or more in two out of four preceding fiscal years.
Exchange of information
The Global Anti-Base Erosion (GloBE) Information Return (GIR) provides the framework for the reporting, and exchange, of information in relation to the Global Minimum Tax (Pillar Two).
Ireland has signed, and activated, the Multilateral Competent Authority Agreement on the GloBE Information Return (GIR MCAA).
Council Directive 2011/16/EU (DAC) provides for the exchange of taxpayer information between the tax administrations of European Union (EU) Member States. Council Directive (EU) 2025/872 (DAC9) amended the DAC to transpose the GIR into EU law.
DAC9 supports the implementation and administration of Council Directive (EU) 2022/2523, which transposes the OECD Pillar Two (GloBE) rules into EU law.
DAC9 (the GIR MCAA) provide the legal basis for the cooperation and exchange of information relating to the:
Irish legislation and guidance
Section 94 of the Finance Act (No. 2) 2023 (further amended by the Finance Act 2024) transposed Council Directive (EU) 2022/2523 into Irish domestic law. This can be found in Sections 111A-111AAAE Part 4A of the Taxes Consolidation Act (TCA), 1997, and is supported by Statutory Instrument (S.I.) No. 675 of 2023.
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