Intent: Discussions can involve seeking changes to legislation and seeking to influence policy (although TALC is largely a tax administration forum it is not always possible to decouple the issues from the underlying legislation and policy).
Details: A range of taxation matters related to Direct and Capital Taxes are discussed at these TALC subcommittee meetings, many technical and administrative matters arise, but legislation and policy can also be relevant.
Meeting on 25 June 2026.Meeting of the Residential Zoned Land Tax [RZLT] Subgroup on 12 May 2026 to discuss administrative issues and the implementation of RZLT.Further meeting of the Residential Zoned Land Tax [RZLT] Subgroup on 8 July 2026 to discuss administrative issues and the implementation of RZLT. - MeetingSubmission to Revenue on 27 May 2026 to provide feedback on the draft Proposed Partnership Section to be inserted into TDM Part 08-02-01. - Submission
Intent: To discuss matters relating to international tax including the EU tax simplification package; Revenue guidance on anti-hybrid/loss-making branches and Pillar Two - global minimum taxation.
Details: Meeting of the TALC BEPS Implementation Sub-committee. (The minutes of this meeting have been published by TALC).
Email to Revenue on 19 May 2026 seeking clarification on the completion of the GloBE Information Return (GIR) for out-of-scope entities and jurisdictions and claims for safe harbours. - EmailMeeting on 17 July 2026.Meeting of the TALC BEPS Pillar Two Administration Subgroup on 9 June 2026 (The minutes of this meeting have been published by TALC).Further meeting of the TALC BEPS Pillar Two Administration Subgroup on 26 June 2026 (The minutes of this meeting have been published by TALC).Further meeting of the TALC BEPS Pillar Two Administration Subgroup on 14 July 2026 (The minutes of this meeting have been published by TALC). - MeetingSubmission to Revenue on 21 August 2026 in respect of matters arising from the TALC BEPS Sub-committee Meeting on 17 July 2026 relating to Loss-making Branches and Double-deduction Rules (Hybrid Rules). - Submission
Intent: To provide clearer guidance for Section 110 companies and confirmation of the tax treatment of dividend withholding tax under Schedule 24A for section 110 companies.
Details: Submission to Revenue Commissioners on technical interpretation of Schedule 24A TCA 1997 in the context of Section 110 companies. Request for guidance to outline treatment of carry forward of credits where an Irish company is in a loss position but has a profitable foreign branch that pays foreign t, ...
Intent: To facilitate clearer Revenue guidance on the anti-hybrid rules relating to loss-making branches and the double deduction rules in thecontext of non-trapped loss situations.
Details: Requested Revenue to confirm how a company can claim a deduction for expenses of a branch which have been denied under anti-hybrid rules.
Intent: To facilitate clearer Revenue guidance for share exchange reliefs.
Details: Requested Revenue to provide confirmation in the guidance ‘Company amalgamations by exchange of shares (S.586) – Part 19-04-10' that share exchange reliefs should be interpreted considering the Mergers Directive, where relevant.
Intent: To facilitate simplification and better guidance for S110 companies.
Details: Requested that the Case I carve out included in some of the Tax and Duty Manuals on the tax treatment of stocklending/sale and repurchase (repo) transactions could also be extended to Section 110 companies.
Intent: To ensure that the meaning of “associated entities” is consistent across Revenue guidance materials.
Details: Requested Revenue to clarify the meaning of “associated entities” in the context of partnerships and the Outbound Payment Defensive Measures. We raised the fact that the definition is discussed differently in other guidance materials.
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
