Pearse Doherty (Donegal, Sinn Fein) | Oireachtas source

The issue here is the location. We understand the location of subsidiaries is not just an issue in taxation; it is access to markets and all of the rest.

The issue relates to subsidiaries based in Ireland of major multinational companies headquartered in America, of which there are many. If the United States does not adopt pillar 2 after 202, the State will be obligated to ensure the Irish subsidiaries apply the UTPR and, therefore, would charge the tax that should be collected by the United States Administration and it would come into the Irish coffers, which would cause major issues in terms of the company and international tax law. I assume in a scenario where the likes of US and other key blocs opt out of pillar 2, these issues will have to be examined all over again.