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 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 will be available through Revenue Online Service (ROS) in March 2026. For further information, please see Key dates and updates.
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