Revenue has published new guidance on the registration process for Pillar Two taxes. Entities must register with Revenue for the relevant taxes within twelve months following the end of the first fiscal year in which they fall within the scope of Pillar Two taxes which includes taxes arising under the Income Inclusion Rule (IIR), the Undertaxed Profit Rule (UTPR), and/or the Qualified Domestic Top-up Tax (QDTT).
The guidance outlines the relevant Pillar Two registration obligations and provides information on the registration hub and managing the various registrations. The registration hub is now live and the deadline for in-scope entities with a fiscal year ending on or before 31 December 2024 to register with Revenue for Pillar Two is 31 December 2025
Entities are also required to register for the Top-up Tax Information Return (TIR) through the registration portal, enabling them to inform Revenue whether the TIR will be filed in Ireland or by a Designated Filing Entity in another jurisdiction.
Revenue issued letters to Irish Ultimate Parent Entities (UPEs) in mid-August 2025 regarding the registration process and a second phase of letters are due to be issued soon to the constituent entities of the Irish UPEs.
Further details on the registration portal and the dedicated Revenue Pillar Two hub are outlined in our recent news item.
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