Ireland: Guidance on GIR filing and notification requirements under Pillar Two

Irish Revenue on May 26, 2026, issued detailed guidance on the global anti-base erosion (GloBE) information return (GIR) filing and notification requirements under the Pillar Two rules.

Key clarifications include:

• May 18 common understanding: The guidance refers to the OECD common understanding for the first reporting year and notes that, if the GIR is centrally filed in a jurisdiction listed in the Annex on or before the specified filing deadline, the multinational enterprise (MNE) group is not required to undertake local GIR filing in any other 2024 implementing jurisdiction, provided it has complied with the notification requirements in that local jurisdiction. This approach applies on the basis that these exchange relationships are expected to be activated and exchanges completed on or before December 31, 2026.
• Partial GIR filing: If an implementing jurisdiction cannot rely on central filing and exchange mechanisms, local filing may be required. In such cases, the information provided must be consistent with that contained in the centrally filed GIR, and the local filing is only required to contain the information that the tax authority would have received under the dissemination approach if reliance had been placed on central filing and exchange mechanisms.
• QDMTT-only jurisdictions: A jurisdiction that has implemented only a QDMTT cannot act as a central filing jurisdiction and will not disseminate GIR information to other jurisdictions. However, such jurisdictions may receive GIR information from other jurisdictions, based on their taxing rights under the GloBE rules.
• Validation and errors: The guidance includes a 48-page list of validation errors aligned with the OECD rules, DAC9 requirements, and GIR XML schema. In addition, the guidance notes that the OECD is expected to publish additional interpretative guidance in May 2026, which includes the switch-off of certain validation rules.
• Future updates to the GIR XML schema: Subject to updates planned by the OECD and the European Commission (EC), the structure of the standardized XML schema is not expected to change for the 2024 and 2025 fiscal years. The OECD continues to engage on an updated version of the GIR XML schema, including potential changes required in respect of the Side-by-Side package. Further revisions to the GIR XML schema may be introduced that apply for fiscal years 2026 onwards.

Read a June 2026 report prepared by KPMG’s EU Tax Centre