Irish Tax Institute

Lobbying Organisation Irish Tax Institute

Date published 21 May, 2026

Relevant Matter Legislation

Public Policy Area Taxation

Period 1 Jan. 2026 to 30 Apr. 2026

Specific Details Meeting of the TALC BEPS Implementation Sub-committee. (The minutes of this meeting will be published by TALC).

Intended results To discuss matters relating to international tax including Revenue guidance on the participation exemption for certain foreign dividends, outbound payments defensive measures and Pillar Two - global minimum tax.

Name of person primarily responsible for lobbying on this activity Anne Gunnell

Did any Designated Public Official(DPO) or former Designated Public Official(DPO) carry out lobbying activities on your behalf in relation to this return? You must include yourself, and answer Yes, if you are a current DPO or a DPO at any time in the past. (What is a Designated Public Official?) No

Did you manage or direct a grassroots campaign? No

Was this lobbying done on behalf of a client? No

Lobbying activity

The following activities occurred for this specific Subject Matter Area.

Meeting (1)

Meeting on 27 February 2026. Meeting of the TALC BEPS Pillar Two Administration Subgroup on 17 February (The minutes of this meeting have been published by TALC). Further meeting of the TALC BEPS Pillar Two Administration Subgroup on 20 March. (The minutes of this meeting have been published by TALC). Further meeting of the TALC BEPS Pillar Two Administration Subgroup on 28 April. (The minutes of this meeting will be published by TALC).

Email (2-5)

Email to Revenue on 23 January with feedback on the Revenue guidance relating to the outbound payments defensive measures in respect of Investment Limited Partnerships. Email to Revenue on 6 March with feedback on a proposed update to Revenue's guidance on the Pillar Two rules relating to Article 3.2.7 of the OECD Commentary (High-Tax Counterparty using mixture of losses).

Email (2-5)

Email to Revenue on 30 March with feedback on the Top-up Tax Information Return (TIR)/GloBE Information Return (GIR) and clarification from HMRC on information required where no jurisdiction has taxing rights. Email to Revenue on 30 April with feedback on the proposed GIR Testing Facility and Pillar Two registration issues for MOCEs that are members of two MNE groups.

Submission (2-5)

Submission to Revenue on 13 February with queries relating to Pillar Two registration and filing. Submission to Revenue on 20 February with feedback on matters arising from the meeting of 22 October 2025 on Loss-making Branches and Double-Deduction Rules (Hybrid Rules). Submission to Revenue on 12 March with queries relating to Pillar Two registration and filing. Submissions to Revenue on 20 and 21 April with queries and examples relating to Pillar Two GloBE Information Return (GIR) filings.

Designated public officials lobbied

The following DPOs were lobbied during this return period on this specific Subject Matter Area. These DPOs were involved in at least one of the Lobbying Activities listed above, but not necessarily all of them. As returns are specific to a Subject Matter Area the above Lobbying Activities may be associated with multiple returns.

Jeanette Doonan Assistant Secretaries or Equivalent Grades (The Office of the Revenue Commissioners)

Therese Bourke Assistant Secretary (The Office of the Revenue Commissioners)