Key dates and updates
Registration
The necessary functionality to allow registration of in-scope entities is now available on the Revenue Online Service (ROS). This will enable entities to meet the 31 December 2025 registration deadline.
Note
The Pillar Two registration deadline has been extended to 28 February 2026.
Revenue has commenced contacting potential in-scope entities in relation to Pillar Two registration requirements. We will carry out this process in phases, starting with groups with an Irish Ultimate Parent Entity.
Pay and file
The necessary IT developments required to allow return filing and payment of associated liabilities will be available on ROS in March 2026. This will enable entities to meet the 30 June 2026 deadline for pay and file.
Top-up tax information return (TIR)
The necessary IT developments required to allow the filing of the top-up tax information return will be available on ROS in March 2026. This will enable entities to meet the 30 June 2026 pay and file deadline.
Side-by-Side package
On 5 January 2026, the OECD and 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
- and
- changes to the treatment of substance-based tax incentives.
The package is available on the Economic Co-operation and Development’s (OECD) 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).