Live now: Ireland's Pillar Two Hub and registration system become active
In a significant move, the Irish Revenue has started issuing Pillar Two Registration Letters to in-scope groups as part of a phased approach. The Pillar Two rules, introduced by Ireland in 2023 under the OECD's Base Erosion and Profit Shifting (BEPS) 2.0 initiative, aim to ensure a minimum effective tax rate of 15% in each jurisdiction of operation for in-scope multinational enterprise (MNE) groups and large-scale domestic groups.
The relevant Pillar Two returns and self-assessments are due for filing within 15 months from the end of the fiscal year, extended to 18 months if the fiscal year is a Transition Year. Entities must notify Irish Revenue of any change in the information provided within 12 months of the end of the fiscal year in which the change occurred.
In-scope entities with a fiscal year ending on or before 31 December 2024 must register for the relevant Pillar Two taxes (Qualified Domestic Top-Up Tax (QDTT) and/or Income Inclusion Rule (IIR)) by 31 December 2025. For entities with a calendar-year taxpayer, the registration deadline is 31 December 2025.
To facilitate simplified tax filing and payment arrangements, entities are encouraged to form a QDTT Group or UTPR Group for their Irish entities before the registration deadlines. Simplified tax filing and payment arrangements are available if all Irish entities of a group elect to form a QDTT Group as part of the registration process.
Registration should be completed via Irish Revenue's Revenue Online Service (ROS). Each group should decide on the relevant filing entity for the group in advance of the registration deadlines. Entities must provide details about their constituent entities, assess their tax liability, decide on the designated local entity (DLE), and determine whether a QDTT Group will be formed, among other actions.
Taxpayers are advised to consult their tax advisors to discuss Pillar Two registration and compliance obligations. They should also analyze GIR Multilateral Competent Authority Agreement coverage and plan for information exchange regarding the TIR. Failure to register could result in a penalty of €10k.
The Irish tax authorities launched the Pillar Two Hub and registration platform on 14 August 2025. For assistance with Pillar Two registration, taxpayers can contact Ernst & Young (Ireland) with multiple contacts in Dublin, Cork, Limerick, Galway, and other locations, or Ernst & Young LLP (United States) with contacts in New York and San Jose.
The Alert was published by NTD's Tax Technical Knowledge Services group, with Carolyn Wright as the legal editor. The contacts and email addresses for all listed advisors can be found in the GTNU version of the Alert. The feature on ROS allowing taxpayers to file the relevant Pillar Two tax returns is expected to be available in 2026.
In conclusion, the Pillar Two tax registration deadlines are fast approaching for in-scope entities in Ireland. It is crucial for affected taxpayers to prepare and consult with their tax advisors to ensure compliance and avoid penalties.
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