Intent: To exchange views with the Revenue Board and its Management Committee on a range of administrative tax matters at an informal meeting with the Institute leadership and Institute Council members.
Details: General meeting between the Institute's Council & Executive Team and Revenue's Board & its Management Committee.
Intent: 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.
Details: Meeting of the TALC BEPS Implementation Sub-committee. (The minutes of this meeting will be published by TALC).
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). - EmailEmail 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. - EmailMeeting 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). - Meeting
Intent: To discuss the Finance Bill 2025 amendments relating to the Participation Exemption for Foreign Dividends and Part 4A TCA 1997 (Pillar Two Rules).
Details: Meeting of the TALC BEPS Implementation Sub-committee. (The minutes of this meeting will be published by TALC).
Email to Revenue on 14 October 2025 requesting clarification at the TALC BEPS meeting on the preparation of a qualified CBCR report in the context of the Pillar Two Transitional CBCR Safe Harbour. - EmailMeeting on 22 October 2025. - MeetingSubmission to Revenue on 21 October 2025 with feedback on Finance Bill 2025 amendments to Part 4A TCA 1997 (Pillar Two) and the participation exemption for certain foreign distributions. Submission to Revenue on 19 December 2025 with feedback in response to the agreed actions points from the meeting of 22 October. - Submission
Intent: Clarification on the policy rationale for the application of this rule regarding withholding tax in the context of section 831B TCA 1997.
Details: We raised our concerns regarding the application of withholding tax and exclusion of entities from the participation exemption for certain foreign distributions where a partial or nominal refund of tax applied as announced in Finance Bill 2025.
Intent: Clarification on how a branch can get a deduction for a non-trapped loss where a deduction was initially denied under hybrid rules.
Details: Requested Revenue to provide guidance on the treatment of loss-making branches and the double deduction rules in the context of non-trapped loss situations.
Intent: A range of Base Erosion and Profit Shifting (BEPS) issues are discussed at these TALC subcommittee meetings. Legislation and policy can be discussed in addition to administrative matters.
Intent: A range of Base Erosion and Profit Shifting (BEPS) issues are discussed at these TALC subcommittee meetings. Legislation and policy can be discussed in addition to administrative matters.