Irish Tax Institute

Lobbying Organisation Irish Tax Institute

Date published 21 Jan, 2025

Relevant Matter Legislation

Public Policy Area Taxation

Period 1 Sep, 2024 to 31 Dec, 2024

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

Intended results To discuss the Finance Bill 2024 amendments relating to the implementation a Participation Exemption for Foreign Dividends, Part 4A TCA 1997 (Pillar Two Rules) and transfer pricing.

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 16 October 2024.

Submission (2-5)

Three submissions to Revenue: 20 September 2024 - feedback on draft updated Pillar Two guidance circulated to the TALC BEPS Implementation Sub-committee. 15 October 2024 - feedback on Finance Bill 2024 amendments relating to the implementation of a Participation Exemption for Foreign Dividends, Part 4A TCA 1997 (Pillar Two Rules) and transfer pricing. 25 November 2024 - feedback on updated draft Pillar Two guidance relating to Section 111AAC TCA 1997 post Finance Act 2024.

Email (2-5)

Emails to Revenue on 16, 17 & 30 October and 17 December 2024 with feedback on the introduction of a participation exemption; the Finance Bill 2024 amendments to Part 4A (Pillar Two); the updated draft Pillar Two guidance relating to umbrella and sub-fund structures; and where investment entities and insurance investment entities are subject to differing treatment under the Pillar Two Rules.

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)