Key dates and updates
Registration
In-scope entities can use the Revenue Online Service (ROS) to register for Pillar Two.
The deadline for registration for in-scope entities is 12 months after the end of their first fiscal year. By way of exception, in-scope entities with their first fiscal year ending in 2024 were required to register by 31 December 2025. This deadline was later extended to 28 February 2026.
For further information, please see Registering for Pillar Two.
Pay and file
The necessary IT developments required to allow return filing and payment of associated liabilities are now available in ROS. This enables entities to meet the first Pillar Two pay and file deadline of 30 June 2026.
For further information, please see Preparing for Pillar Two and Pay and file for Pillar Two.
Top-up tax information return (TIR)
The necessary IT developments required to allow the filing of the Top-Up Tax Information Return (TIR) are now available in ROS. This enables entities to meet the first TIR filing deadline of 30 June 2026.
Revenue has made a test environment available to assist filers with their TIR filing preparations. We have also published a user guide for additional support. For further information, please see:
Side-by-Side package
On 5 January 2026, the Organisation for Economic Co-operation and Development (OECD) and the G20 Inclusive Framework on Base Erosion and Profit Shifting approved and adopted a Side-by-Side package for Pillar Two. The Side-by-Side package includes:
- a Side-by-Side system setting out rules to facilitate existing minimum tax regimes
- simplification measures
- changes to the treatment of substance-based tax incentives.
The package is available on the OECD's website.
On 12 January 2026, the European Commission published Commission Notice C/2026/253. This notice acknowledges the OECD’s Side-by-Side package and confirms its application in the context of Council Directive (EU) 2022/2523 (The Minimum Tax Directive).
Recognition of Cyprus as a qualified IIR jurisdiction
On 29 May 2026, the European Commission clarified that European Union (EU) Member States should treat Cyprus as having a qualified Income Inclusion Rule (IIR) in effect.
Multi National Enterprises (MNEs) should adopt this position in the TIR which is due to be filed by 30 June 2026. For further information, please see the European Commission website.
Common understanding of jurisdictions implementing Pillar Two from 2024
As the TIR or GIR filing deadline approaches, it is anticipated that some jurisdictions implementing Pillar Two from 2024 may not have a fully operational filing portal. In addition, MNE groups may not have certainty on the activation of certain exchange agreements by the TIR/GIR deadline.
The OECD published a paper on 18 May 2026 setting out a common approach some jurisdictions are adopting to alleviate uncertainty. Ireland is adopting this common approach. Under this approach, Revenue will not enforce local filing for a period of six months from the filing deadline if all of the following conditions are met:
- If a TIR or GIR is centrally filed in one of the jurisdictions included in the Annex to the OECD’s paper.
- Revenue receives the relevant information from that jurisdiction within six months of the filing deadline.
- The MNE group has met their notification of filer obligations in Ireland.
This common approach will apply where the TIR or GIR filing deadline is no later than 31 December 2026.