Top-up Tax Information Return (TIR)

What is the TIR?

All entities in scope of the Pillar Two rules must file a Top-up Tax Information Return (TIR) with Revenue. A TIR is a mandatory information return containing the data required under the Pillar Two rules. It contains data on a multinational enterprise group's:

• structure
• financial data
• and
• calculations for each jurisdiction in which it operates.

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.

Note

The TIR is also referred to as the Global Anti-Base Erosion (GloBE) Information Return. The 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.

Council Directive 2011/16/EU (DAC) provides for the exchange of certain taxpayer information between the tax administrations of European Union (EU) Member States. In 2025, the DAC was amended by Council Directive (EU) 2025/872 (DAC9). DAC9 provides for the automatic exchange of the TIR information between EU Member States.

The TIR must be completed in accordance with DAC9. Finance Act 2025 transposes DAC9 into domestic legislation. The TIR will be available on the Revenue Online Service (ROS) in March 2026.

Entities that file a GIR must do so in accordance with the requirements of the Pillar Two model rules. The Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA) was published by the OECD in January 2025.

The GIR MCAA provides for the automatic exchange of GloBE information between GIR MCAA Signatory tax administrations if not provided for under DAC9.

Next: Meeting the TIR compliance requirements