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 was seeking for stakeholder views on the implementation of the Pillar Two Minimum Tax Rate proposal in Ireland. The consultation period ran until July 22, 2022.

On December 9, 2022 the Irish Ministry of Finance published the responses it received on its consultation. The Irish Government received feedback from a total of 11 responders. A high-level review of the responses shows that most respondents are of the opinion that one of the main reasons that Ireland was successful is because of its tax friendly tax climate and that a creform of the Irish corporation tax regime will be key to Ireland’s success at retaining and attracting foreign direct investment.

Suggestions include the amending of the he R&D tax credit regime and the Knowledge Development Box (KDB) so that they will qualify as a Qualified Refundable Tax Credit (QRTC) for Pillar 2. Another suggestion is that commencing January 1, 2023 an optional participation exemption for taxpayers for foreign income sources is introduced.

The responses that were published on the website of the Irish Ministry of Finance can be donloaded here:

• Aircraft Leasing Ireland (ALI);
• The American Chamber of Commerce Ireland (AmCham);
• Arthur Cox;
• The Consultative Committee of Accountancy Bodies–Ireland (CCAB-I);
• Deloitte;
• EY;
• Ibec (Ireland’s largest business representative);
• Insurance Ireland;
• Irish Tax Institute (ITI);
• KPMG; and
• PWC.

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