Preparing for Pillar Two

Overview

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 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.

Due to the complexity of the Pillar Two rules, it is important to understand how these rules apply to you as an in-scope entity.

Next: Initial preparation considerations

Published: 29 July 2026 Print this page

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