Pearse Doherty (Donegal, Sinn Fein) | Oireachtas source

That is fair enough, and that is a fair assessment, given that the administration's stated public intention is to sign up to pillar 2. The income inclusion rule, which allows for a parent company to apply the minimum effective tax to a subsidiary in a low tax jurisdiction or a jurisdiction that does not operate under pillar 2, and the UTPR, which allows a subsidiary to charge the tax on the parent company that is not allowing for it, was never designed for major economic blocs not to be part of it. If the agreement at international level unravels among larger blocs, obviously political negotiations and skill will be needed to bring that about again. That is my view of how we would have to move forward on this because it would bring up serious issues otherwise. The rules we have that would be applied to major economic blocs were never intended for that purpose. They were intended for a subsidiary in the Cayman Islands or somewhere like that as opposed to a major advanced economy that has opted out of pillar 2.

Is the consolidated version of the GLoBE rules on the Minister's agenda in respect of assisting with compliance? I am conscious that penalties have been deferred until 2028 but what is the Government planning to do in this regard? Our provisions are very closely aligned with the OECD model rules. Is any consolidated version being looked at?