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BEPS 2.0: OECD Pillar One and Pillar Two

  • article

    Pillar Two – What are your filing obligations?

    Pillar Two is now in force in Ireland, with the effect that a 15% minimum effective corporation tax rate applies to large corporate groups and standalone entities with a turnover of €75...

    Tax
  • publication

    ALG responds to the Department of Finance’s Second Feedback Statement on Pillar 2

    On 27 July 2023 the Department of Finance published its second feedback statement the draft legislation to implement the OECD’s Pillar 2 Rules.

    Tax
  • publication

    ALG responds to the Department of Finance’s First Feedback Statement on Pillar 2

    On 31 March 2023 the Department of Finance published its first feedback statement the draft legislation to implement the OECD’s Pillar 2 Rules.

    Tax
  • article

    EU agreement reached for Pillar 2 Directive and commitment to Pillar 1 rules reaffirmed

    Almost a year after the EU Commission presented a proposal for a directive to implement the Pillar 2 rules, the EU Member States on 12 December 2022 reached the necessary unanimous agreement to...

    Tax
  • article

    Irish Finance Bill 2022 amendments related to the OECD Pillar Two Rules

    The Irish Finance Bill 2022, which is due to be enacted this month, December 2022, provides for changes to the Irish research and development (R&D) tax credit and Knowledge Development Box...

    Tax
  • article

    The Two-Pillar solution – What are the key developments?

    We look here at recent key developments on the two-pillar solution and the statement published by the OECD/G20 Inclusive Framework last October, which dealt with a number of key...

    Tax
  • article

    Implementation of Pillar 1 and 2 and BEPS

    This article provides a snap shot of what has happened since the agreement reached on 8 October 2021 by 136 jurisdictions of the OECD/G20 Inclusive Framework.

    Tax
  • article

    Ireland agrees to sign up to OECD Inclusive Framework political agreement on the OECD two-pillar approach

    Ireland will sign up to the OECD Inclusive Framework political agreement on the two-pillar approach, following approval by the Irish Cabinet.

    Tax
  • article

    G20 agreement on Pillars 1 and 2

    On 10 July 2021, the G20 endorsed that broad framework for Pillars 1 and 2 and the ambitious timetable for bringing the new rules into force in 2023.

    Tax
  • Article

    OECD Inclusive Framework Agreement reached on BEPS 2.0

    There has been a further breakthrough in the process to reach international agreement on the BEPS 2.0 proposals, aimed at  addressing  the tax challenges arising from the digitalisation of the economy. 

    Tax
  • article

    G7 Finance Ministers reach consensus on Pillar 1 and Pillar 2 proposals

    On Saturday 5 June 2021 the G7 finance ministers reached political consensus on proposals for a global minimum corporation tax of at least 15% to be determined on a country by country basis.

    Tax
  • article

    The EU Commission sets out its immediate tax policy agenda

    The European Commission's "Communication on Business Taxation for the 21st Century", published on 18 May 2021, sets out a number of tax proposals it aims to have implemented in the immediate future.

    Tax
  • publication

    OECD Global Minimum Taxation Rules and IP Regimes

    The OECD Pillar Two Blueprint published on 12 October 2020 is aimed at addressing challenges relating to the taxation of the digital economy.

    Tax
  • article

    A deal on BEPS 2.0 could cost Ireland 20% of its corporation tax revenues

    Speaking at an Irish Department of Finance international tax seminar, held virtually on 21 April 2021, Irish Finance Minister Pascal Donohue indicated that the cost to Ireland of agreement on BEPS 2.0 is...

    Tax
  • publication

    Overview of the Pillar 1 Proposed Tax Dispute Resolution Process

    Pillar 1 of BEPS 2.0 is made up of two parts.  One part, Amount A allocates a portion of deemed residual profits of certain in-scope multinational enterprises (MNE) to market jurisdictions.

    Tax
  • audio

    Inconsistencies in the US approach to BEPS 2.0 Project?

    Philip McQueston, Of Counsel, spoke with US and Brazilian attorney José Rubens Scharlack about inconsistencies José sees in the US position concerning the BEPS 2.0 project, highlighted in a recent article...

    Tax
  • article

    ALG contributes to the IBA Taxes Committee submission to the OECD regarding the blueprints

    On 12 October 2020, the OECD/G20 Inclusive Framework on BEPS released the Pillar One and Pillar Two Blueprints, together with a public consultation document seeking stakeholder input on the Blueprints.

    Tax
  • article

    Consultation on the BEPS 2.0 blueprints

    What could be the final public consultation meeting on the BEPS 2.0 blueprints will be held this week on 14 and 15 January 2021.

    Tax
  • publication

    Background to the Blueprints and the OECD Two-Pillar Approach

    The matter of directly addressing the tax challenges of the digitalised economy was effectively parked in the course of the OECD’s base erosion and profit shifting (BEPS) project.

    Tax
  • publication

    Key features of Pillar One and Pillar Two

    On 12 October 2020, the OECD published its reports on the ‘Blueprints’ for its two-pillar proposal to address both the tax challenges arising from the digitalisation of the economy and the remaining...

    Tax