Revenue eBrief No. 244/25

18 December 2025

Update to Tax and Duty Manual Part 04A-01-01A - Guidance on Pillar Two – Registration

Tax and Duty Manual Part 04A-01-01A (Guidance on Pillar Two – Registration) is updated as follows:

Extension of registration deadline

• For in-scope entities whose first fiscal year ends in 2024, the Pillar Two Tax registration deadline is extended to 28 February 2026 (from 31 December 2025) - see paragraph 2.2.               

Other key updates regarding inactive / dormant entities, dissolved entities and entities with no active tax registration

• A new paragraph is inserted at 2.1.1 detailing a new Revenue administrative practice for inactive or dormant entities that meet certain conditions.
• A new paragraph is inserted at 2.1.2 setting out Revenue’s administrative practice in circumstances where there is a dissolved entity in the MNE group.
• A new paragraph is inserted at 2.1.3 giving guidance on the registration process for entities that do not have an active tax registration.
• Paragraph 2.5.1 is updated to clarify the ROS permissions required by users using a ROS sub-user certificate.
• Paragraph 4.1.4 was removed as the amend fiscal year function is no longer available.
• Appendix E – is updated to include guidance on approving agent link requests within 30 days, and requirements for an MNE group registering using its own TAIN DigiCert.