On 12 October 2026, Minister of State Frank Feighan led the Irish delegation to the 2026 Annual Meetings of the International Monetary Fund (IMF) and World Bank Group in Bangkok, Thailand. The meetings provided a critical platform for advancing the international tax reform agenda, particularly the finalization of the OECD/G20 Inclusive Framework’s Two-Pillar solution. Ireland participated in high-level discussions on the Multilateral Convention (MLC) to implement Amount A of Pillar One, the Subject to Tax Rule (STTR) under Pillar Two, and the design of the Global Minimum Tax Implementation Package for developing countries. Minister Feighan also held bilateral meetings with counterparts from the United States, United Kingdom, and key EU partners to align positions ahead of the Inclusive Framework plenary scheduled for November 2026.
Key Takeaways
- Pillar One MLC Progress: Negotiators reported substantial progress on the MLC text, with a target for signature by mid-2027; Ireland advocated for clear certainty mechanisms for small open economies and robust marketing and distribution profits safe harbors.
- STTR Treaty Integration: Ireland confirmed its intention to incorporate the Subject to Tax Rule into its bilateral tax treaty network via the MLC, ensuring that treaty benefits are denied on intra-group payments taxed below 9% in the residence jurisdiction, effective for treaties entering into force after 31 December 2026.
- Support for Developing Economies: Ireland pledged €1 million to the IMF’s Tax Policy Division to assist low-income countries in building administrative capacity for Pillar Two implementation, including legislative drafting, IT systems for top-up tax collection, and dispute resolution readiness.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement