Irish Revenue opened the online registration portal for Pillar Two registration on 15 August 2025. The registration must be completed via the Revenue Online System (ROS).
Further guidance is awaited from Irish Revenue on the registration process.
Which entities are required to register?
Irish Constituent Entities that are within scope of the Pillar 2 rules must file a one-time registration with Irish Revenue within 12 months of the end of the first Fiscal Year to which the Pillar 2 rules apply to the MNE (i.e. fiscal years beginning on or after 31 December 2023).
Therefore, for groups with a 31 December year-end, the registration should be completed by 31 December 2025.
Importantly, registration is required for groups within scope even if no Top-up Taxes are due.
The registration applies to entities which are within the scope of (i) the Income Inclusion Rule (IIR), (ii) the Undertaxed Profits Rule (UTPR), and/or (iii) the domestic top-up tax (QDTT) in Ireland. More details are available here.
Process for filing
The registration portal is now live and the process for registering is online via the Revenue Online System and it is possible for an agent, such as KPMG, to register on behalf of the entity.
Where KPMG is not the registered tax agent, then it may be necessary to obtain authorisation from the company.
What information needs to be reported for the initial notification?
To complete the online form, following information will be required:
- The name of the Entity
- TIN (tax identification number) of the Entity
- Tax/Taxes for which the Entity is registering (IIR, UTPR, or QDMTT)
- Details in respect of the UPE (Name, Location, TIN)
- The first Fiscal Year to which the Irish Pillar 2 rules apply to the Entity
- Information in respect of the Designated Filing Entity of the MNE group (if applicable)
- Information in respect of the Designated Local Entity
- Information in respect of the QDTT group (if applicable)
- Information in respect of the UTPR group (if applicable)
A detailed Information Request List can be provided on request.
Practical considerations
- Irish Revenue intends to directly contact entities who they believe are within the scope of Pillar 2 in relation to the registration requirements. This will be carried out on a phased basis, starting with groups with an Irish Ultimate Parent Entity. However, it’s not necessary to await this communication before completing the registration process.
- An entity must notify the Irish Revenue Commissioners of any change to the information provided in the notice within 12 months of the end of the fiscal year in which the change occurred.
- Where an entity is no longer subject to the Irish domestic top-up tax, they must cease their registration. The entity must notify Revenue within 12 months of the end of the first fiscal year it is no longer subject to the top-up tax.
- Where an entity fails to submit the required registration or fails to update the registration details or de-register, there is a potential penalty of €10,000.
Tax Return filings
The first Pillar 2 tax returns and payment obligations will be due by 30 June 2026 (i.e. 18 months after the end of the first fiscal year) and Irish Revenue confirmed that the new online tax return system should be available in early 2026.
Get in touch
Please reach out to Cillein Barry for assistance with the registration process. We look forward to hearing from you.
