On 20 July 2021, the Irish Minister for Finance, Paschal Donohoe, announced a public consultation on the Organisation for Economic Co-operation and Development (OECD) International Tax Proposals – the two-pillar solution commonly referred to as “BEPS 2.0.”

As background, on 1 July 2021, the OECD Inclusive Framework reached agreement but not unanimous consensus on key aspects of this two-pillar solu…