As multinational enterprises (MNE’s) continue to get to grips with Pillar Two and looming compliance deadlines, there have been a number of updates in Ireland and the EU which are worth exploring. The key takeaways from this alert are:

• Taxpayers within the scope of Pillar Two will need to register with Revenue by 31 December 2025. We expect Revenue will make the registration portal available from sometime this Summer, facilitating timely registration. The data that is expected to be required from taxpayers is outlined below.
• There is updated Revenue Guidance on Pillar Two, which is technical in nature and reflects changes to the Irish legislation in 2024. The up to date guidance is linked here: Part 04A-01-01 and Part 04A-01-02.
• The EU has enacted DAC 9 which incorporates the OECD Pillar Two Globe Information Return requirements into EU law and establishes the framework to facilitate the automatic exchange of top-up tax information between Member States. It is to take effect in 2026 (i.e. it will be in effect for 2024 returns which are to be filed by June 2026.

Read on to understand the above in more detail.

1. Pillar Two Registration in Ireland – what we know.

In scope Irish taxpayers are required to register with Revenue within 12 months of the end of the first fiscal year (‘FY’) in which the entity is subject to each of the Qualified Domestic Top-up Tax (‘QDTT’), Income Inclusion Rule (‘IIR’) and / or Untaxed Profits Rule (‘UTPR’). For 31 December year end entities in scope for 2024, this means registration by 31 December 2025. We understand that Revenue hope to have the registration process operational and live on Revenue’s Online Service over the Summer. We expect that in terms of the registration requirements, Revenue will likely stick close to the requirements outlined in section 111AAH of the Taxes Consolidation Act 1997 (‘TCA 97’), which outlines the following information must be provided as part of the registration process:

• The name and Irish Tax Identification Number (‘TIN’) of the entity registering.
• The tax or taxes the entity is registering for and the first financial year the tax or taxes would be applicable.
• The name, location, and TIN of the Ultimate Parent Entity.
• The name and TIN of an entity that has been appointed as the designated local entity (‘DLE’) and the name, location and TIN of an entity that has been appointed as the designated filing entity (‘DFE’).
• Where the entity itself has been appointed as the DLE, the name and TIN of the other constituent entities of the group in Ireland.
• Details of any group filing election made under QDTT or UTPR, namely:
  • Election to become a member of the QDTT/UTPR group
  • The name of the QDTT / UTPR group filer.
  • The TIN of the QDTT / UTPR group filer.
  • Where the entity is the QDTT / UPTR group filer, notification confirming the fact.
• Any other information Revenue may reasonably require.

We understand that Revenue intends to write to taxpayers, in Q3 of 2025, who they believe (based on Country-by-Country reporting data) should fall within the scope of Pillar Two to request them to register or confirm they are out of scope.

Further insight on the registration process should be available soon and we will keep you updated as this develops.

2. Revenue Tax and Duty Manual (‘TDM’) on Pillar Two Update

Revenue issued an eBrief (098/2025) on 8 May confirming certain minor updates to the Pillar Two TDMs as follows:

• Finance Act 2024 introduced a number of amendments to Pillar 2 legislation which are effective for accounting periods commencing on or after 31 December 2024. This included anti-abuse rules for hybrid arbitrage arrangements in the context of accessing the transitional safe harbours and tracking of deferred tax. Section 4 of the TDM Part 04A-01-02 (‘the P2 TDM’) has been updated to provide that Revenue is prepared to accept the application of those provisions to a fiscal year or an accounting period which commences prior to 31 December 2024. This allows taxpayers to accelerate the application of these provisions, if they so wish, so that they are effective in 2024 instead of 2025.
• In cases where top-up tax payable by the QDTT or UTPR group filer is not paid within 12 months of the date on which the tax was due, an authorised officer may serve a notice related to the unpaid liability on a member of the QDTT or UTPR group. Sections 8 and 11 of TDM Part 04A-01-01 have been updated to confirm that this notice will not be served on a securitisation entity where there is another non-securitisation entity in the QDTT or UTPR group to which the top up tax liability of the securitisation entity is allocated.

3. DAC 9

The EU Pillar 2 Directive and Irish legislation implementing the Pillar 2 Directive allow for the central filing of the Top up Tax Information Return (Globe Information Return (GIR) under OECD model rules) provided that the return is made by the UPE or a designated filing entity located in a jurisdiction with which Ireland has a qualifying authority agreement*. DAC 9 constitutes such a qualifying authority agreement between Member States, incorporates the OECD GIR requirements into EU law and establishes the framework to facilitate the automatic exchange of information between Member States. To share top-up tax return information with non-EU countries, Member States will need to sign appropriate international agreements.

DAC 9 entered into force on 7 May 2025 and Member States must transpose the directive into their domestic law by 31 December 2025.

MNEs are expected to file their first Top up Tax Information Return by 30 June 2026. Under DAC 9, the relevant tax authorities must exchange this information with each other by 31 December 2026 at the latest. However, from Year 2 the authorities will only have 3 months after the filing deadline in which to exchange the relevant data.
In scope taxpayers should assess where it would be most appropriate to file the Top up Tax Information Return and whether there may be advantages to filing it in Ireland as opposed to elsewhere.

*Bilateral or multilateral agreement or arrangement between two or more competent authorities that provides for the automatic exchange of top up tax information returns.

4. Conclusion

EY will continue to monitor and provide updates on developments related to Pillar Two, in particular as the compliance deadlines fast approach. Please reach out to your regular contacts to discuss further.