On May 26, 2022 the Irish Government opened a public consultation on the implementation of Pillar Two (the introduction of a 15% minimum Effective Tax Rate). Through this consultation the Irish Ministry of Finance is seeking stakeholder views on the implementation of the Pillar Two Minimum Tax Rate proposal in Ireland. The consultation period will run until July 22, 2022.

25 questions are raised in the consultation document that are ordered in accordance with the Chapters of the Proposal for a Council Directive on ensuring a global minimum level of taxation for multinational groups in the Union.

Furthermore the Irish Ministry of Finance asks for input regarding the following four questions of a more general nature:

1.  Are there any specific features of the Rules that warrant particular attention with regard to their implications for Ireland’s tax code and tax policy?

2.  When implementing the Rules, are there any specific issues which should be considered with respect to implications for the Irish tax code arising from US corporate tax reform proposals, with particular reference to the significance of US MNEs operating in Ireland?

3.  Are there other considerations of significance that should be taken into account when implementing the Rules in domestic legislation?

4.  Are there any amendments needed to Ireland’s existing tax code to ensure that existing legislation does not result in any unintended outcomes under the Rules when they are implemented in domestic legislation?

The consultation document as published on May 26, 2022 by the Irish Ministry of Finance can be downloaded here.

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