DAC9/GIR

Top-up Tax Information Return (TIR) reporting obligations

All entities in scope of Pillar Two rules must file a Top-up Tax Information Return (TIR) with Revenue.

The TIR must be filed no later than 15 months after the end of each fiscal year. This period is extended to 18 months for the first fiscal year that an entity is in scope. The same timelines apply in other Pillar Two implementing jurisdictions.

Note

The TIR is also referred to as the Global Anti-Base Erosion (GloBE) Information Return. The term GloBE Information Return (GIR) is referenced in the Organisation for Economic Co-operation and Development's (OECD's) Pillar Two model rules.

There are four ways which an entity can meet their TIR filing obligation:

1. Each constituent entity of the Multinational Enterprise (MNE) group located in Ireland files a TIR with Revenue.
2. A constituent entity may appoint a designated local entity to prepare and file the TIR with Revenue on behalf of the constituent entity. No more than one entity in an MNE group or large-scale domestic group may be appointed as the designated local entity.
3. The ultimate parent entity files the TIR or GIR with a tax authority in another jurisdiction.
4. A designated filing entity (DFE) files the TIR or GIR with a tax authority in another jurisdiction.

An entity filing a TIR or GIR in another jurisdiction must ensure:

• that jurisdiction has implemented DAC9 or has signed the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCCA)
• the GIR MCAA has been activated, where applicable
• a notification of filer is received by Revenue by the specified return date.

The OECD has published the following information to provide information to in-scope entities on the TIR:

• OECD GloBE Information Return
• OECD Model Rules and Commentary
• Activation status of GIR MCAA signatories

For further information on the TIR, please see Top-up Tax Information Return (TIR).

Next: How to file a Top-up Tax Information Return (TIR)