Revenue eBrief No. 125/26
28 August 2026
Guidance on Pillar Two
Tax and Duty Manual Part 04A-01-02 (Global Minimum Level of Taxation for Multinational Enterprise Groups and Large-Scale Domestic Groups in the Union) provides guidance in relation to the operation of the Pillar Two rules.
Sections 8.9 and 9.8 of the manual have been updated in relation to prior period adjustments, in particular, prior year adjustments relating to a pre-transition fiscal year that have an impact on deferred tax expense.
Section 9.1 has been updated to refer to OECD Administrative Guidance regarding the computation of the effective tax rate for Pillar Two.
Miscellaneous cross references to OECD Administrative Guidance documents have been updated, including in section 1.1 and in Appendix 1.