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Ireland’s Department of Finance, on 31 March, published a Pillar Two feedback statement. The statement sets forth proposed Irish legislation to implement Pillar Two, including confirmation of the intention to introduce a Qualified Domestic Top-up Tax (QDTT). 

This feedback statement builds on a previous consultation process held in 2022 around implementing the EU Minimum Tax Directive in Ireland. Interested parties have until 8 May 2023 to respond as part of this process.

Action Item: The feedback statement indicates important policy decisions as to the QDTT, administration, and operation of the new tax. Pillar Two will be the biggest change to Ireland’s tax system in decades and will require close analysis by a wide range of stakeholders to manage the implementation process. The willingness of the Department of Finance to consult widely with stakeholders and practitioners is welcome, and businesses should consider responding to the specific questions asked or more generally about the proposed legislation by the 8 May deadline.