Ireland’s 2025 Finance Bill Includes January 2025 OECD Administrative Guidance Amendments

On October 16, 2025, Ireland published its 2025 Finance Bill. This includes amendments for the January 2025 OECD Administrative Guidance, DAC 9 implementation as well as other technical amendments.

January 2025 OECD Administrative Guidance

Section 92 of the Finance Bill 2025 includes the deferred tax recognition amendments to Articles 9.1 of the GloBE Rules in the January 2025 OECD Administrative Guidance (including the grace period for DTA reversals). The consequential amendments to the Transitional CbCR Harbour and the QDMTT Safe Harbour are also included.

GIR MCAA/DAC9

Section 92 of the 2025 Finance Bill also provides for the implementation of DAC 9 and the OECD Pillar Two MCAA for GIR filing. This includes the relevant information sharing provisions. 

The GIR is filed under DAC 9 where the ultimate parent entity or designated filing entity which files the return is located in an EU Member State. If not, the GIR is filed as provided by the OECD GIR Guidance. 

Other Amendments

The 2025 Finance Bill includes various other amendments to its Pillar 2 law, including:

-An amendment to the definition of ultimate parent entity (UPE) in section 111A to clarify that it excludes an orphan entity where there is another entity in the group that is not an orphan entity and meets the definition of a UPE.

-The Finance Act 2024 included a new Section 111AAC(4) in the primary law to implement the June 2024 OECD Administrative Guidance for securitisation entities. It provides for the domestic top-up tax liability in respect of a securitisation entity to be imposed on another constituent entity of the MNE group or, where the top-up tax liability cannot be otherwise collected, on the securitisation entity itself. The 2025 Finance Bill includes a further amendment to provide that any QDMTT calculated for a securitisation entity that is a minority-owned constituent entity will be allocated to other group members.