Top-up Tax Information Return (TIR)

Meeting the TIR compliance requirements

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

The TIR must be filed with Revenue 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 OECD's Pillar Two model rules. Non-EU jurisdictions implementing the Pillar Two rules may accept a GIR instead of a TIR.

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 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 MCAA)
• and
• a notification of filer is received with Revenue by the specified return date.

Entities filing a TIR in another jurisdiction may only file in a jurisdiction that is a signatory to the GIR MCAA or an EU Member State. There must be an active TIR exchange agreement in place between Ireland and that jurisdiction.

Next: Notification of filer