Irish Revenue recently issued their first guidance relating to BEPS Pillar Two in Tax and Duty Manual (TDM) Part 04a-01-02.

What does the Guidance cover?

The guidance gives a high level overview of the background and principles of the Pillar Two rules including the income inclusion rule (IIR), undertaxed profit rule (UTPR), qualified domestic top-up tax (QDTT) and relieving provisions such as the substance based income exclusion and safe harbours.
The guidance also contains a useful table which cross references the Irish legislation to the EU Directive and Model Rules.

What is next?

The TDM will be expanded by Irish Revenue in due course to include further guidance on Pillar Two, in particular on issues raised at the Tax Administration Liaison Committee (TALC). Guidance on substantive issues is likely only to be included in the TDM when confirmed by the OECD. Further guidance from the OECD on specific issues including securitisation vehicles is understood to be imminent. It is expected that there will be at least two further rounds of OECD guidance later this year.