I propose to take Questions Nos. 253, 255, 256 and 257 together.
I will first address Question No. 253 (Ref: 51299/26), as the Deputy will be aware, Ireland joined the global consensus in reaching a political agreement at the OECD Inclusive Framework on BEPS in October 2021, to sign up to a two-pillared solution to the tax challenges arising from the digitalisation of the economy. Pillar Two of this agreement includes a commitment to introduce a 15 per cent global minimum effective tax rate for multinational enterprises with an annual turnover in excess of €750 million, located in in-scope jurisdictions, through the GloBE Rules. Ireland, together with our fellow EU Member States, implemented Pillar Two by transposing the EU Minimum Tax Directive effective for fiscal years beginning 31 December 2023 and later.
In addition, more than 60 other jurisdictions have implemented all or elements of the Pillar Two framework, with many others having published draft legislation or announcing their intention to apply Pillar Two rules in the near future. The first fiscal year of a multinational enterprise to which Pillar Two applies in Ireland is 2024, with the first payments and filing of top-up tax returns due from 30 June 2026. Similar to Corporation Tax, the Pillar Two rules are linked to the financial reporting period for in-scope entities, and as such not all multinational enterprise will have the same tax reporting deadline.
I am advised by Revenue that to estimate imposing a minimum effective tax rate of 20% would require detailed modelling and could have a significant impact on the behaviour and decisions of large companies. Therefore, it is not possible to provide a reliable estimate of any yield that may accrue to the Exchequer at this time.
In relation to Questions No. 255 (Ref: 51301/26), 256 (Ref: 51302/26) and 257 (Ref: 51303/26), the trading profits of companies in Ireland are generally taxed at the standard Corporation Tax (‘CT’) rate of 12.5%. Some of the main features of the current regime are its simplicity and that it applies to a broad base.
Imposing additional taxes on certain sectors would involve increased complexity and could change the attractiveness of Ireland's corporate tax regime. While it is possible that imposing such taxes could lead to theoretical gains, there is a risk of such taxes leading to lower levels of economic activity and to companies passing the additional tax burden onto their suppliers or consumers.
In respect of Question No. 255 (Ref: 51301/26), I am advised by Revenue that, on the basis of information included in the CT returns filed for the tax year 2024, the potential yield from imposing a 4% levy on the profits of private human health and pharmaceutical companies, including nursing homes and home care agencies, is tentatively estimated to be in the region of €1,541 million. It has been assumed that the levy would apply to the taxable profits of pharmaceutical companies, nursing homes and home care agencies, but would not apply to medical practices or private hospitals. Additionally, the potential yield assumes no behavioural change on the part of these companies.
In respect of Question No. 256 (Ref: 51302/26), I am advised by Revenue that the data available to Revenue on companies' turnover is not sufficient to support the statistical breakdown requested. Consequently, the estimate provided relates to the application of the proposed levy to all ICT companies on Revenue's record, that is, it includes both companies with turnover above €750 million and those below that threshold. The estimate is based on the industry classification code assigned to each company on Revenue's records. It does not include any yield that might arise from subsidiaries of these companies where those subsidiaries are not themselves primarily engaged in the sectors referred to in the question. On the basis of CT returns filed for the 2024 tax year, the tentative estimated yield from applying a 2.25% levy to the profits of all ICT companies is approximately €1,248 million. This estimate again assumes no behavioural change on the part of the companies concerned in response to the introduction of the levy.
In respect of Question No. (Ref: 51303/26), I am advised by Revenue that the data available to Revenue on companies' turnover is not sufficient to support the statistical breakdown requested. Consequently, the estimate below relates to the application of the proposed levy to all grocery companies on Revenue's record, that is, it includes both companies with turnover above €50 million and those below that threshold. The estimate is based on the industry classification code assigned to each company on Revenue's records. It does not include any yield that might arise from subsidiaries of these companies where those subsidiaries are not themselves primarily engaged in the sectors referred to in the Question. On the basis of CT returns filed for the 2024 tax year, the tentative estimated yield from applying a 20% levy to the profits of all grocery companies is approximately €67 million. This estimate assumes no behavioural change on the part of the companies concerned in response to the introduction of the levy.
I am advised by Revenue that it has no specific category/marker which would enable it to identify companies as “fast food retailers”. However, an estimate can be provided for the imposition of a 10% levy on the profits of all companies with the industry classification “food and beverage service activities”. I am further advised by Revenue that the data available to Revenue on companies' turnover is not sufficient to support the statistical breakdown requested. Consequently, the estimate below relates to the application of the proposed levy to all food and beverage service companies on Revenue's record, that is, it includes both companies with turnover above €25 million and those below that threshold. The estimate is based on the industry classification code assigned to each company on Revenue's records. It does not include any yield that might arise from subsidiaries of these companies where those subsidiaries are not themselves primarily engaged in the sectors referred to in the Question. On the basis of CT returns filed for the 2024 tax year, the tentative estimated yield from applying a 20% levy to the profits of all food and beverage service activities companies is approximately €67 million. This estimate assumes no behavioural change on the part of the companies concerned in response to the introduction of the levy.