Ireland: Updated Pillar Two guidance

Updated guidance on application and administration of Pillar Two rules

Irish Revenue on March 24, 2026, published updated guidance on the application of the Irish minimum taxation rules (Pillar Two), as well as guidance on administration of the Pillar Two rules.

Topics covered in the guidance include:

Compliance requirements under Pillar Two, including new obligations stemming from the Council Directive (EU) 2025/872 (DAC9) and the GloBE Information Return Multilateral Competent Authority Agreement (GIR MCAA)
Updated technical interpretation of Pillar Two rules, such as the treatment of orphan entities and securitization entities, allocation of undertaxed profits rule (UTPR) top-up tax among domestic entities, intragroup financing, and confirmation that the loss-related deferred tax assets (DTAs) may only be recognized as adjusted covered taxes when they genuinely reverse and are utilized
Updates to clarification on the application of the qualified domestic top-up tax (QDMTT) safe harbor and transitional country-by-country reporting safe harbor (TCSH)
Clarifications on when the local Generally Accepted Accounting Principles (GAAP) may be used for QDMTT calculation purposes even if the fiscal year of a constituent entity differs from that of the ultimate parent entity (UPE)

Read an April 2026 report prepared by KPMG’s EU Tax Centre

The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.

Relevant Results

Ireland: Updated Pillar Two guidance

Contact KPMG

Headline