Cross-border Tax Talks

May 30, 2024

Pillar Two in Ireland: It takes a village

Doug McHoney (PwC's Global International Tax Services Leader) and Peter Reilly (PwC International Tax Partner & Ireland’s Tax Policy Leader) are at PwC EMEA’s International Tax Academy in Prague to discuss Ireland’s implementation of Pillar Two. Doug and Peter dive into why Irish policy makers agreed to adopt the Pillar Two regime, how Ireland is incorporating the OECD guidance, the potential effects on the Irish economy and current tax regime, the ways Irish multinationals are preparing, and the potential ramifications in the future. 

Timestamps:

  • 1:30 - Which recognizable celebrity also lives in Peter’s hometown of Monkstown, Ireland?
  • 3:00 - What is the background for Ireland agreeing to a 15% minimum tax?
  • 6:15 - Will Pillar Two impact foreign direct investment in Ireland?
  • 7:54 - Any estimate of how much revenue Pillar Two will raise in Ireland?
  • 13:06 - What is the status of Pillar Two in Ireland, including the IIR, UTPR, QDMTT?
  • 14:41 - How is Ireland implementing the OECD administrative guidance? 
  • 17:56 - Has Ireland released any information on filing of returns?
  • 19:27 - What accounting standard is Ireland using for the QDMTT?
  • 20:49 - How is Ireland’s tax incentive regime being affected by Pillar Two?
  • 23:58 - How are Irish multinationals dealing with Pillar Two’s data requirements?
  • 31:04 - Will the OECD’s Administrative Guidance ever be finalized?
  • 32:55 - How are governments and taxpayers going to react to the uncertain tax landscape in 2025? 
  • 35:51 - What is the status of Ireland’s participation exemption for foreign dividends, and are there other Irish tax changes on the horizon? 

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Speakers

Doug McHoney

Principal, Quantitative Solutions and Technology, International Tax Services Global Leader, PwC US

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Peter Reilly

Partner, Dublin, PwC Ireland (Republic of)

+353 87 6458394

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Doug McHoney

Doug McHoney

Principal, Quantitative Solutions and Technology, International Tax Services Global Leader, PwC US

Geoff Jacobi

Geoff Jacobi

ITS, Knowledge Management Managing Director, PwC US

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