Top-up Tax Information Return (TIR)
Transitional simplified jurisdictional reporting
During a transitional period of five years, Multinational Enterprises (MNEs) can elect to report under a simplified jurisdictional reporting framework. The transitional period is the period of fiscal years beginning on or before 31 December 2028 and ending on or before 30 June 2030.
Where certain conditions are met, MNE groups can report data on a jurisdictional basis, rather than on a constituent entity by constituent entity basis.
A Qualified Domestic Top-up Tax (QDTT) group filer may file a domestic top-up tax return with Revenue on behalf of all Irish QDTT group members. In this situation, the MNE may elect to complete the Top-up Tax Information Return (TIR) using the simplified jurisdictional reporting framework.
Completing the TIR in line with this simplified jurisdictional reporting framework, can also be applied to top-up taxes arising in jurisdictions other than Ireland. This is on the basis that there is no charge to:
However, if there is a charge to either tax, there is no requirement for taxes to be allocated on a constituent entity by constituent entity basis.
For further information, please see section 18 in Tax and Duty Manual Part 04A-01-01.
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