Irish Revenue Clarifies Exclusion of Pre-Transition Tax Adjustments from Pillar Two ETR

The Irish Revenue has issued eBrief No. 150/25 (31 July 2025) updating Tax and Duty Manual Part 04A-01-02 on the Global Minimum Level of Taxation (Pillar Two).

The revised guidance provides for the following changes:

• Any decrease in “covered taxes” booked in the current year but relating to a pre-transition fiscal year must be excluded from the jurisdictional effective-tax-rate (ETR) and top-up-tax computations for that current year;
• The aforesaid change is also valid when applying the tra…