Revenue eBrief No. 058/26

24 March 2026

Guidance on Pillar Two

Two Tax and Duty Manuals (TDMs) relating to Pillar Two have been updated to reflect changes made to the Pillar Two legislation in Part 4A Taxes Consolidation Act 1997 by Finance Act 2025:

TDM Part 04A-01-01 - Global Minimum Level of Taxation for Multinational Enterprise Groups and Large-Scale Domestic Groups in the Union - Administration, which contains an overview of the Administration of Pillar Two.

The changes are as follows:

• Updates with respect to the requirements of the Directive on Administrative Cooperation and the OECD Pillar Two Multilateral Competent Authority Agreement (MCAA); 
• To reflect that the secondary collection mechanism for UTPR and QDTT liabilities do not apply to a securitisation entity in certain circumstances;
• Updates with respect to the taxpayer obligation to keep records, the provision of related penalties for non-compliance, and Revenue’s power to inspect records.

   

TDM Part 04A-01-02 - Global Minimum Level of Taxation for Multinational Enterprise Groups and Large-Scale Domestic Groups in the Union, which provides guidance in relation to the operation of the Pillar Two rules.

The changes are as follows:

• in section 5.1, to update guidance in respect of ultimate parent entities;
• in section 6.10, to update guidance in respect of section 111N - Calculation and allocation of UTPR top-up tax amount, as it relates to the allocation of UTPR among domestic constituent entities;
• in section 7.2, to update guidance in respect of intra-group financing arrangements and use of losses carried forward;
• in section 8.5 (section 111X – Total deferred tax adjustment amount) and section 12.1 (section 111AW – Tax treatment of deferred tax assets, deferred tax liabilities and transferred assets upon transition), as it relates to the utilisation of loss deferred tax assets;
• in section 9.6, to update guidance in respect of section 111AH - Minority owned constituent entities, as it relates to an orphan entity that is a constituent entity;
• in section 9.7 (section 111AI - Qualified domestic top-up tax safe harbour);
• in section 9.8 (section 111AJ - Transitional CbCR safe harbour) and section 12.1 (section 111AW – Tax treatment of deferred tax assets, deferred tax liabilities and transferred assets upon transition), as it relates to the treatment of certain deferred tax assets (DTA’s) arising from tax benefits provided by General Government;
• in section 13.3, to update guidance in respect of section 111AAC - Chargeable entities, as it relates to the reallocation of any QDTT calculated for a securitisation entity that is a minority owned constituent entity;
• in section 13.4, to update guidance in respect of Section 111AAD - Determining top-up tax amounts of qualifying entity, as it relates to the application of the local accounting standard in calculating domestic top-up tax, in certain circumstances, notwithstanding that the fiscal year end does not align with that of the ultimate parent entity.

A number of other minor amendments have been reflected throughout the TDMs.