Ireland Tax Agency Issues Guidance on Global Minimum Tax Registration for MNE, Large-Scale Domestic Groups

The Irish Revenue Commissioners Sept. 5 issued Revenue eBrief No. 170/25, on new guidance concerning the registration process for domestic taxes ensuring global minimum taxation for multinational enterprise (MNE) groups and large-scale domestic groups under the OECD’s Pillar Two. The guidance includes that: 1) mandatory registration applies for in-scope entities subject to the domestic income inclusion rule (IIR) top-up tax, undertaxed profits rule (UTPR) top-up tax, or domestic top-up tax (QDTT); 2) the registration deadline is no later than 12 months after the last day of the first fiscal year to which a domestic top-up tax applies; 3) registration is ...