DAC9/GIR
Registration obligations for filers
The Pillar Two rules apply to Multinational Enterprise (MNE) groups or large-scale domestic groups. These rules apply where the revenue of the group exceeds €750 million in two of the previous four fiscal years. All entities in scope of the Pillar Two rules must file a Top-up Tax Information Return (TIR) with Revenue.
The Pillar Two rules include an Income Inclusion Rule (IIR) and an Undertaxed Profits Rule (UTPR). The rules also allow jurisdictions to introduce a Qualified Domestic Top-up Tax (QDTT).
Entities located in Ireland must register with Revenue if they are subject to any of the following:
Entities must register within 12 months of the end of the first fiscal year they come within scope.
The deadline for registration for in-scope entities with their first fiscal year ending in 2024 was 31 December 2025. This deadline was later extended to 28 February 2026.
You can register for Pillar Two now through the Revenue Online Service (ROS).
Where a Designated Filing Entity (DFE) is appointed, the designation should be notified via Notification of Filer (NOF), so that Revenue can rely on central filing for Pillar Two purposes.
For further information, please see Registering for Pillar Two.
Next: The Top-up Tax Information Return (TIR)