Revenue eBrief No. 098/25

08 May 2025

Guidance on Pillar Two - Administration

The following two Tax and Duty Manuals (TDMs) relating to Pillar Two have been updated:

• TDM Part 04A-01-01 - Global Minimum Level of Taxation for Multinational Enterprise Groups and Large-Scale Domestic Groups in the Union - Administration, which contains an overview of the Administration of Pillar Two. The TDM has been updated at sections 8 and 11 to outline how the UTPR and QDTT group recovery provisions will be applied where a securitisation entity is part of a UTPR group or a QDTT group.

• TDM Part 04A-01-02 - Global Minimum Level of Taxation for Multinational Enterprise Groups and Large-Scale Domestic Groups in the Union, which provides guidance in relation to the operation of the Pillar Two rules. Section 115(2) of Finance Act 2024 provides that certain of the amendments to Part 4A TCA 1997 shall apply in respect of a fiscal year (within the meaning of section 111A TCA 1997) or an accounting period, as the case may be, commencing on or after 31 December 2024. The updated TDM confirms that Revenue is prepared to accept the application of those provisions, at the discretion of the taxpayer, to a fiscal year or an accounting period, as the case may be, which commences prior to 31 December 2024.