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Research and Development (R&D) Tax Credit
Immigration Services – Financial Verification
Pillar II
Foreign Direct Investment
International Tax Strategy

Pillar II

If your company has annual revenues of €750 million or more or is part of a group with consolidated annual revenues of €750 million or more, the global minimum effective tax rate of 15% will impact you.

The Pillar II provisions came into effect in Ireland on 1st January  2024. This means that MNEs operating in Ireland and falling within the scope of the GloBE rules must ensure compliance with the new Pillar II provisions.


Key Mechanisms of Pillar II:

  • Income Inclusion Rule (IIR): Imposes top-up taxes at the parent company level if subsidiaries fall below the 15% minimum ETR.

  • Undertaxed Payment Rule (UTPR): Ensures appropriate taxation of cross-border payments to mitigate profit shifting.

  • Qualified Domestic Minimum Top-Up Tax (QDMTT): Allows jurisdictions to establish their own minimum tax provisions aligned with Pillar II.

These measures seek to create a level playing field for global taxation and reduce incentives for profit shifting to low-tax jurisdictions, potentially increasing tax liabilities for companies operating in such areas.
 

Expanded Compliance Obligations

The introduction of Pillar II represents a significant shift in international and Irish taxation, leading to new compliance and reporting requirements for businesses. Companies within its scope must navigate complex tax filings across various jurisdictions and will need to collect and analyse extensive financial and non-financial data, often dispersed across multiple systems. Adapting internal processes, updating systems, and training tax and finance teams will place additional demands on resources.

To assist with this transition, temporary Safe Harbour rules will be in effect until fiscal years ending in 2028, simplifying compliance and reducing administrative burdens for qualifying businesses.
 

Pillar II Advisory Services by Moore Ireland

We provide a comprehensive suite of services designed to help your business navigate the challenges of Pillar II, ensuring compliance while optimising processes and mitigating risks. Our offerings include:

  1. Impact Assessment and Risk Evaluation:

    • Conduct a "heat mapping" analysis to identify high tax exposure jurisdictions.

    • Model effective tax rates (ETRs) and calculate potential top-up taxes.

    • Assess eligibility for Safe Harbour provisions and their benefits.

  2. Data Mapping and Gap Analysis:

    • Identify necessary data for GloBE calculations, including structured and unstructured financial information.

    • Analyse existing systems to identify data gaps and implement measures to address them.

  3. Education and Training:

    • Equip internal tax and finance teams with the knowledge to understand and apply Pillar II rules.

    • Provide ongoing technical guidance to ensure adaptability to evolving regulations.

  4. Compliance Management and Reporting:

    • Develop systems to ensure real-time compliance across jurisdictions with varying timelines.

    • Assist in preparing GloBE Information Returns and other required filings.

  5. Long-Term Strategy Development:

    • Design and implement robust target operating models tailored to your business needs.

    • Offer continuous monitoring and support to adapt to legislative changes.
       

Software Solution

Our tailored software solution offers an efficient approach to Pillar II compliance, seamlessly integrating with your existing systems or being fully implemented within your operational framework.
Key features include:

  • Comprehensive Data Collection and Analysis: Consolidates data from multiple sources for accurate GloBE calculations.

  • Phase-Based Implementation:

    • Phase 1: Map business units and their tax treatment.

    • Phase 2: Supplement data for GloBE calculations.

    • Phase 3: Identify entities qualifying for Safe Harbour and generate interim reports.

    • Phase 4: Provide a final overview of additional tax accruals based on GloBE calculations.

  • Customisable Features: Adapt the tool to your specific needs, including ERP integration and reporting automation.
     

Why Partner with Us?

  • Expertise Across Borders: Our team possesses extensive knowledge of Irish and international tax law, ensuring you remain compliant with regulatory changes.

  • Tailored, End-to-End Support: We provide customised plans that address your unique needs, from initial scoping to ongoing compliance.

  • Technology-Driven Efficiency: Our cutting-edge software and streamlined processes simplify complex calculations and reduce administrative burdens.

  • Global Insights with Local Expertise: We monitor legislative developments across jurisdictions, offering timely advice to keep you compliant and competitive.

 

Pillar II Guidance

Our tax experts are here to help you achieve compliance with Pillar II while also improving your tax planning and reporting processes. Connect with our team today.