Michael McGrath (Cork South Central, Fianna Fail) | Oireachtas source

Transitional penalty relief will be provided for the transitional period in line with published OECD guidance. This guidance provides that during a transitional period no penalties or sanctions should apply in connection with the filing of the GLoBE information return, GIR, where a tax administration considers that a multinational entity has taken reasonable measures to ensure the correct application of the pillar 2 rules. A tax administration may consider that a multinational enterprise has taken reasonable measures where the multinational enterprise can demonstrate that it has acted in good faith to understand and comply with the relevant domestic application of the pillar 2 rules. The transition period is for fiscal years beginning on or before 31 December 2026 but not including a fiscal year that ends after 30 June 2028. The transitional penalty relief will be provided for the transitional period in line with OECD guidance.