Top-up Tax Information Return (TIR)

Exchange of information

Council Directive (EU) 2022/2523 of 15 December 2022, ensures a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the European Union (EU). This Directive was transposed into Irish law by Part 4A of the Taxes Consolidation Act (TCA), 1997, and is referred to as the Minimum Tax Directive.

The Minimum Tax Directive requires entities to file a Top-Up Tax Information Return (TIR). Council Directive (EU) 2025/872 (DAC9) provides for the automatic exchange of the TIR information between EU Member States.

The TIR is also referred to as the Global Anti-Base Erosion (GloBE) Information Return. The GloBE Information Return (GIR) is referenced in the Organisation for Economic Co-operation and Development's (OECD'S) Pillar Two model rules.

The Multilateral Component Authority Agreement on the Exchange of GloBE Information (GIR MCAA) provides for the automatic exchange of the GIR information between GIR MCAA signatory tax administrations.

Finance Act 2025 provides domestically for the exchange of TIR or GIR information under DAC9 and the GIR MCAA. Tax authorities, including Revenue, must exchange the first TIR or GIR information with each other by 31 December 2026, at the latest. Information will be exchanged between tax authorities following the dissemination approach.

Note

The ‘dissemination approach’ is a process approved by the OECD/G20 Inclusive Framework on BEPS under the GIR MCAA. This process ensures that jurisdictions only receive the data relevant to its jurisdiction.

For further information on top-up tax information return, please see Preparing for Pillar Two.