Revenue eBrief No. 109/26

26 June 2026

Pillar Two filing deadline – 30 June 2026

Filers are reminded that entities in-scope of the Pillar Two rules with an accounting period ending 31 December 2024 are due to file their information returns (TIR or NoF) and their domestic tax returns (IIR, UTPR or QDTT) by 30 June 2026 and pay any associated liabilities.

Filing is strong in advance of the deadline. To date, Revenue has received over 40 TIRs, 700 NoFs, and over 600 domestic returns across the three Pillar Two tax-heads; QDTT, UTPR and IIR. 

Updated guidance – TIR and NoF

Tax and Duty Manual Part 04A-10-02 is updated in appendix B, to include information on resolving XML schema and validation errors. The appendix includes links to resources to assist TIR filers diagnose issues, validation rules disabled for TIR filing on ROS, and feedback on queries raised by filers about specific rules.  The PIT User Guide is also updated to include the new appendix.

Under “central filing”, a constituent entity is not obliged to file a TIR where the TIR is delivered to a tax authority in another jurisdiction by the ultimate parent entity or designated filing entity located in a jurisdiction that has a qualifying competent authority agreement in effect with the State for the relevant fiscal year.  Revenue is aware that certain jurisdictions where groups intend to complete a central filing have indicated that no late filing penalties will be charged if the submission of a TIR has been made by a certain date after the specified return date, that is a date which is later than 18 months following the end of the fiscal year. Revenue is prepared to accept that where:

• a correct and complete TIR is filed in such jurisdiction on behalf of a constituent entity located in Ireland on or before the earlier of

(i) the date to which penalties will not apply in that jurisdiction, and

(ii) 30 September 2026, and

• a NoF has been submitted to Revenue on or before the specified return date,

then the central filing mechanism as provided for in section 111AAI(2) TCA 1997 may continue to be available to the constituent entity located in Ireland and late filing penalties in respect of the TIR will not apply.