On July 20, 2021 the Irish Ministry of Finance launched a public consultation regarding the two-pillar solution to address the tax challenges arising from the digitalisation of the economy. The Irish Ministry of Finance is inviting replies from interested parties. The consultation period will run from July 20, 2021 to September 10, 2021.


The Irish Ministry of Finance shaped the public consultation in the form of the following seven questions:

1.  Do you have views on the broad policy objectives of the OECD international tax proposals?

2.  Are there specific implications for Ireland’s corporation tax regime that would arise from adopting and implementing the OECD proposals that require particular consideration? What are the benefits and challenges for Ireland?

3.  Are there specific features in the design of the Pillar One proposals which, in your opinion, may have particular implications for Ireland and our tax policy?

4.  Pillar Two proposals include agreeing to adopt an Income Inclusion Rule, an Under-Taxed Payments Rule and a Subject To Tax Rule. Are there any specific features of introducing these rules that warrant particular attention with regard to their implications for Ireland’s tax code and tax policy?

5.  Are there any specific issues which should be considered in respect to implications for the Irish tax code arising from the GILTI, SHIELD and other US corporate tax reform proposals, with particular reference to the significance of US MNEs in Ireland?

6.  Are there specific considerations of particular significance that should be taken into account in deciding how any final agreement should be implemented?

7.  Are there any further considerations that should be taken into account, including in respect to Ireland’s wider industrial policy arising from the OECD proposals?


Click here to download the consultation document in which you can also find detailed information on how to provide your input for this public consultation.



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