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: 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 broad range of issues related to Base Erosion and Profit Shifting (BEPS) and related taxation matters are discussed at these TALC subcommittee meetings. Many technical and administrative matters arise, but legislation and policy can also be relevant.
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 broad range of taxation matters are discussed at Main TALC Meetings, many technical and administrative matters arise, but legislation and policy can also be relevant.
Call with Revenue on 16 December 2025 to discuss difficulties with Pillar Two Registrations relating to dormant and dissolved entities. - Phone callEmail to Revenue on 5 December 2025 with feedback on the difficulties being encountered by members with Pillar Two registrationsFollow up email to Revenue on 11 December 2025 regarding difficulties being encountered by members with Pillar Two registrations.Email to Revenue on 18 December 2025 requesting clarification on the application of the extended Pillar Two registration deadline to any entity due to register on or before 31 January 2026. - EmailMeeting on 9 September 2025.Further meeting of Main TALC on 2 December 2025. (The minutes of this meeting will be published by TALC). - Meeting
Intent: To gain a better understanding of the tax administrative issues dealt with by Revenue's Large Corporates Division (LCD). Matters discussed at the meeting include: Change to the threshold for entry to LCD and transition of cases; Priority areas of focus for the sectoral and TP branches; Update on Pillar Two and registration deadline; Update on Automatic Information Exchange; and practitioners’ feedback on engaging with LCD. A Summary Note of the meeting is available on the Institute's website.
Details: Annual Branch Meeting between the Irish Tax Institute and Revenue's Large Corporates Division (LCD).
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). During this period the budget and Finance Bill were of particular relevance.
Details: A broad range of taxation matters are discussed at Main TALC Meetings, many technical and administrative matters arise, but legislation and policy can also be relevant. During this period the budget and Finance Bill were of particular relevance.
A broad range of taxation matters are discussed at Main TALC Meetings, many technical and administrative matters arise, but legislation and policy can also be relevant. During this period the budget and Finance Bill were of particular relevance. - Meeting
