Corporation tax, Pillar Two and the tax treatment of Irish funds
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The introduction of Pillar Two of the OECD BEPS framework (introducing a 15% OECD-wide minimum corporation tax rate) was arguably the first occasion that the promoters of Irish domiciled funds had to consider the application (or not) of a substantive set of corporation tax rules, writes KEVIN GAHAN, a partner In Matheson’s Tax Department. In this article co authored with , MICHELLE DALY and senior associate JEN PRESTON they examine the potential tax issues for the investment funds industry and securitisation structures in Ireland.
In October 2021, OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (the “Inclusive Framework”), a group comprising over 130 member jurisdictions, including Ireland, agreed to tax measures to ensure that large multinational groups would pay a 15% effective corporate tax rate in each jurisdiction where they operate. This followed a political consensus to ensure that large multinationals paid appropriate amounts of tax on their corporate profits.
 

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Kevin Gahan and Michelle Daly are tax partners and Jen Preston is a senior associate at Matheson.
1 Council Directive (EU) 2022/2523 on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the Union.
2https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/global-minimum-tax/administrative-guidance-global-anti-base-erosion-rules-pillar-two-june-2024.pdf
This article appeared in the November 2024 edition.