Barry Cowen (Laois-Offaly, Fianna Fail) | Oireachtas source

I thank the Minister for his response and for the detail contained in it. He has made several points in response. The first one is where he states that we are a small open economy with strong ties to the EU, the US, and the other G20 countries, which is essential for a long-term competitiveness to ensure that we remain in line with key partners. What does the Minister believe is the risk to the US and other G20 countries, from their perspective, of being outside of the agreement?

On the minimum tax directive, which all member states are legally bound to transpose to bring the primary rules into effect by the end of December, this also encompasses the transitional safe harbour which is subject to qualifying international agreements of the OECD. Is the Minister saying categorically that this has to happen by 31 December 2023? Can I have that point clarified?

On the US and the Biden Administration and its commitment with regard to Pillar 1, when does the Minister believe the transition phase will expire? When will Pillar 2 rules be established globally and why does the Minister feel that we should move ahead of the globe?

The other point mentioned by the Minister was that the system allows for an integrated application of GloBE and GILTI rules on an interim basis, allowing for the application of the QDTT in priority by not giving rise to double taxation for businesses through appropriate credit mechanisms. The Minister stated, "This is a significant positive for Ireland and provides stability for businesses as the rules are implemented globally over the coming years." How, essentially, does the Minster believe that this is a positive for Ireland?

The transitional safe harbour will apply for a time-limited period of one year. This means that the UTPR or the backstop would come into effect from the end of 2025. How do we know that it would come in at the end of 2025, specifically?

The Minister stated:

We fully appreciate the concerns by EU-headquartered firms with regard to the potential delay of the application of the Pillar 2 rules globally and the potential distortive impact of the [safe harbour] in the interim. [However] it is important ... to recognise that for international agreements to work, there [has to] be compromise. The rules have been agreed by almost 140 jurisdictions and include limited safe harbours with certain guardrails for valid reasons.

Why should we and the EU compromise before the US agrees an implementation date?