On March 31, 2023, the Irish government issued a Feedback Statement on the Pillar Two Global Minimum Tax.
It includes draft legislation and outlines possible draft legislative approaches to key elements of the GloBE Rules. It is open for comments until May 8, 2023.
A second Feedback Statement is planned to be published in mid-2023, which will include more detailed draft legislation and will reflect the outcome of the consultation. The final draft legislation is planned to be included in the autumn 2023 Finance Bill.
In line with the EU Directive, the draft legislation applies an Income Inclusion Rule (IIR) from fiscal years commencing on or after 31 December 2023, and the Under-Taxed Profits Rule for fiscal years commencing on or after 31 December 2024.
As Ireland’s 12.5% trading rate of corporation tax is below the 15% global minimum rate, Ireland will also include a Qualified Domestic Minimum Top-Up Tax (QDMTT) to ensure it retains primary taxing rights. This is not included in the draft legislation, and the Feedback Statement outlines different approaches that could be taken.
Ireland has already made a number of changes to its tax incentives regimes to reflect the Pillar Two GloBE Rules, see: Irish 2022 Finance Bill Changes for Pillar Two
Unlike most other draft laws that have been published, the draft law includes many of the additional rules that have been published in the OECD Administrative Guidance.
For example:
The draft law addresses substitute loss carry forwards. This reflects Article 2.8 of the OECD Administrative Guidance that provides for the inclusion of deferred tax in the GloBE deferred tax adjustment amount for ‘Substitute Loss Carry Forwards’.
The draft law provides for the Carry-forward of Excess Negative Tax Expenses. As an alternative to incurring additional top-up tax when a domestic tax loss exceeds the GloBE loss, Article 2.7 of the OECD Administrative Guidance provides that an MNE can elect for the Excess Negative Tax Expense administrative procedure. The law implements these provisions.
The draft law applies specific provisions for Blended CFC Regimes (which reflects the OECD Administrative Guidance and includes a simplified formula to allocate CFC taxes in blended CFC regimes such as GILTI for fiscal years that begin on or before 31 December 2025 but not ending after 30 June 2027).
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On December 18, 2025, the Irish Revenue issued Revenue eBrief No. 244/25 which provides for an extension in the Pillar 2 registration deadline to February 28, 2026 (from December 31, 2025).
On December 19, 2025, the Luxembourg Official Gazette published:
– a law to amend its Minimum Tax Law to provide for the January 2025 OECD Administrative Guidance and the EU DAC 9 GIR filing requirements: and
– a Grand Ducal Regulation which includes the format of the GIR
On December 19, 2025, SARS issued further guidance on the Pillar 2 registration process.
Order No. 158/2025 XXV issued on December 12, 2025 provides that for constituent entities whose fiscal year ended between December 31, 2024 and March 31, 2025 the filing deadline for Form 62 (the Pillar 2 Registration Form) is the last day of the 15th month following the end of that fiscal year.
On December 16, 2025, The Netherlands Parliament approved the Second Amendment to the Minimum Tax Act to implement the December 2023, June 2024 and January 2025 OECD Administrative Guidance.
On December 10, 2025, Law No. SFS 2025:1461 to amend the Global Minimum Tax Act was published in the Swedish Official Gazette. The purpose of the law is to implement the provisions of the June 2024 OECD Administrative Guidance into domestic law.
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