Top-up Tax Information Return (TIR)
Overview
The Pillar Two rules include an Income Inclusion Rule (IIR) and an Undertaxed Profit Rule (UTPR). These rules also allow jurisdictions to apply a Qualified Domestic Top-up Tax (QDTT). Ireland elected to introduce a QDTT.
The Pillar Two rules provide that income of large groups is taxed at a minimum effective tax rate of 15% on a jurisdictional basis. The legislation in Part 4A of the Taxes Consolidation Act 1997 provides for the following three taxes:
- IIR top-up tax.
- UTPR top-up tax.
- Domestic top-up tax.
The legislation also provides that every entity in scope of the Pillar Two rules must file a Top-up Tax Information Return (TIR). 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 TIR is available through Revenue Online Service (ROS).
Revenue has made a test environment available to assist filers with their TIR filing preparations. We have also published a user guide for further information.
Next: What is the TIR?