Revenue eBrief No. 150/25
31 July 2025
Global Minimum Level of Taxation for Multinational Enterprise Groups and Large-Scale Domestic Groups in the Union
Tax and Duty Manual (TDM) Part 04A-01-02 - Global Minimum Level of Taxation for Multinational Enterprise Groups and Large-Scale Domestic Groups in the Union - has been updated to reflect certain clarifications with respect to the operation of the Pillar Two legislation in Part 4A Taxes Consolidation Act 1997.
The changes are as follows:
- in section 5.1, to update guidance in respect of insurance investment entities;
- in section 7.2, to update guidance in respect of section 111P - adjustments to determine qualifying income or loss, as it relates to intra-group financing arrangements;
- in section 8.9, to update guidance in respect of section 111AB – Post-filing adjustments and tax rate change, as it relates to covered taxes relating to pre-transition fiscal years and the application of outcomes arising from mutual agreement procedures;
- in section 9.8, to update guidance with respect to section 111AJ - Transitional CbCR safe harbour, as it relates to the calculation of simplified covered taxes relating to pre-transition fiscal years;
- in section 10.2, to update guidance with respect to section 111AM – Constituent entities joining and leaving MNE groups or large-scale domestic groups, as it relates to mergers;
- in section 10.4, to update guidance with respect to section 111AO – Joint ventures, as it relates to interactions with the UTPR, scope of application, unaligned accounting periods and the domestic top-up tax.
A number of other minor amendments have been reflected throughout the TDM including the correction of typographical errors.