Top-up tax information return

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).

The Pillar Two rules provide that income of large groups is taxed at a minimum effective tax rate of 15% on a jurisdictional basis. The legislation in Part 4A of the Taxes Consolidation Act 1997 provides for three taxes:

1. IIR top-up tax.
2. UTPR top-up tax.
3. Domestic top-up tax.

A top-up tax information return must be filed with Revenue using the standardised OECD GloBE information return. The top-up tax information return must be filed with Revenue 15 months after the end of the fiscal year. This period is extended to 18 months for the first fiscal year that the entity is in scope.

The top-up tax information return will be available on the Revenue Online Service (ROS) in early 2026. For further information, please see Key dates and updates. 

There are four ways which the top-up tax information return can be filed:

1. Each constituent entity of the Multi-National Enterprise (MNE) group located in Ireland files a top-up tax information return.
2. A designated local entity is appointed and files the return with Revenue on behalf of all the other entities located in Ireland.
3. The ultimate parent entity files the return with the tax authority in another jurisdiction. That other jurisdiction must have a qualifying competent authority agreement with Ireland which provides for the automatic exchange of top-up tax information returns. Please see the details below in relation to the requirement to file a notification of the filer.
4. A designated filing entity files with the tax authority in another jurisdiction. That jurisdiction must also have a qualifying competent authority agreement with Ireland which provides for the automatic exchange of top-up tax information returns. Please see the details below in relation to the requirement to file a notification of the filer.

Notification of filer

If the ultimate parent entity or designated filing entity files the top-up tax information return in another jurisdiction, an entity located in Ireland must inform Revenue.

The Irish entity must file a notification of the filer 15 months after the end of the fiscal year. This period is extended to 18 months for the first fiscal year that the entity is in scope.

Transitional simplified jurisdictional reporting

During a transitional period of five years, MNEs can elect to report under a simplified jurisdictional reporting framework. The transitional period is the period of fiscal years beginning on, or before, 31 December 2028 and ending on, or before, 30 June 2030.

For further information, please see ‘Transitional simplified jurisdictional reporting’ in the Tax and Duty Manual Part 04A-01-01.

Where certain conditions are met, MNE groups can report data on a jurisdictional basis, rather than on a constituent entity by constituent entity basis.

A Qualified Domestic Top-Up Tax (QDTT) group filer may file a domestic top-up tax return with Revenue on behalf of all Irish QDTT group members. In these cases, the MNE may elect to complete the top-up tax information return using the simplified jurisdictional reporting framework. 

Completing the top-up tax information return, in line with this simplified jurisdictional reporting framework, can also be applied to top-up taxes arising in jurisdictions other than Ireland. This is on the basis that there is no charge to:

• an IIR top-up tax in Ireland
• or
• a UTPR top-up tax in Ireland.

However, if there is a charge to either tax, there is no requirement for taxes to be allocated on a constituent entity by constituent entity basis.