Pearse Doherty (Donegal, Sinn Fein)
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290. To ask the Minister for Finance the estimated share of projected corporation tax that is anticipated to come from multinational corporations subject to the 15% corporate tax rate; and if he will make a statement on the matter. [3068/25]

Paschal Donohoe (Dublin Central, Fine Gael)
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I have assumed that the Deputy is referring in his question to the OECD Pillar Two minimum tax rules, which were implemented in Ireland through the transposition of the EU Minimum Tax Directive in Finance (No. 2 Act) 2023. The Pillar Two rules apply to multinational groups and large-scale domestic groups that have annual revenue of €750 million or more in the consolidated financial statements of the ultimate parent entity of the group in at least two of the four previous fiscal years. The rules require such groups to pay a minimum effective tax rate of 15% on a jurisdictional basis, and by reference to a Pillar Two tax base based on consolidated financial accounts.

The Pillar Two rules have been implemented in Part 4A of the Taxes Consolidation Act (TCA) 1997 and apply in respect of fiscal years commencing on or after 31 December 2023. The first ‘pay and file’ date for groups within the scope of the Pillar Two rules in Ireland is 30 June 2026.

As the scope of the rules is based on consolidated accounting financial data, it is not currently possible to identify all entities which may be in scope. However, an approximation of the number of entities in scope of the rules can be made by using data from country-by-country (CbC) reporting as a multinational group with annual consolidated group revenue of €750m or more in the preceding fiscal year is required to file a CbC report. Therefore, while the scope of the CbC reporting requirements is different, it provides a useful approximation of those entities that will be in scope of Part 4A TCA 1997.

I am advised by Revenue that, based on this approximation, it is estimated that in the years 2021 to 2023, between 68% and 89% of net CT was paid by entities provisionally considered to be within scope of Pillar Two. It is important however to acknowledge that there is a notable band of uncertainty around the potential number of in-scope entities as the Pillar Two rules have distinct differences from existing reporting frameworks. It is further noted that the approximation is based on historical data and cannot take account of future changes in MNE profitability and/or behavioural responses, which may impact on the number of entities in scope. The recent change in administration in the US and its position in relation to the OECD Agreement, together with implementation decisions in other jurisdictions globally, could also have implications in respect of the ultimate economic impact of the introduction of Pillar Two.

Pearse Doherty (Donegal, Sinn Fein)
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291. To ask the Minister for Finance if consideration has been given to extending the period that widows and widowers continue to benefit from being jointly assessed for tax purposes; and if he will make a statement on the matter. [3072/25]

Paschal Donohoe (Dublin Central, Fine Gael)
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I am advised by Revenue that the current position is that where a couple are jointly assessed and one spouse or civil partner dies during a tax year, the following treatment applies:

• In the year of bereavement, the widowed spouse or civil partner is entitled to the same personal tax credits as a married couple, if surviving spouse or civil partner is the assessable spouse or nominated partner.
• If the surviving spouse or civil partner is not the assessable spouse or nominated civil partner, they will receive the increased personal tax credit available to a widowed person or surviving civil partner in the year of bereavement and be assessed on their income from the date of bereavement of the spouse or civil partner until the end of the year.

• Section 461A TCA provides for an additional tax credit for a widowed person or surviving civil partner without dependent children, which may be claimed in the year of assessment following the year of bereavement. The value of this credit is €540 and the widowed person or surviving civil partner is entitled to same in addition to the basic personal tax credit.
• Section 463 TCA provides for the widowed parent tax credit. This tax credit is available in the five years following the year of bereavement for widowed parents and surviving civil partners with dependent children. The credit is tapered over the five years following the year in which the person is bereaved, as follows:

  • €3,600 in the first year after bereavement,
  
  • €3,150 in the second year after bereavement,
  
  • €2,700 in the third year after bereavement,
  
  • €2,250 in the fourth year after bereavement and
  
  • €1,800 in the fifth year after bereavement.

• Section 462B TCA provides for the single person child carer credit (“SPCCC”), which may be available in the years following the year of bereavement where all of the conditions of the provision are met. The SPCCC amounts to €1,900 for the 2025 year of assessment.

Further detailed guidance on the tax treatment of bereaved spouses and civil partners can be found on Revenue Website at: www.revenue.ie/en/life-events-and-personal-circumstances/death-and-bereavement/widowed-person-or-surviving-civil-partner/how-taxed-after-bereavement.aspx

In relation to the Deputy's specific question, I do not currently have any plans to extend the period that widows and widowers continue to benefit from being jointly assessed for tax purposes.