Revenue has published two new guidance manuals providing filing information relating to several Pillar Two tax returns. The new guidance on Top-up tax information return and notification of filer provides a user guide for entities required to file a Top-up tax Information Return (TIR). The TIR has been available for filing since the end of April this year. The guidance titled IIR, UTPR and QDTT Returns and Payments provides guidance on the filing and payment obligations and processes for IIR (Income Inclusion Rule), UTPR (Undertaxed Profit Rule) and QDTT (Qualified Domestic Top-up Tax) returns.
The Top-up tax information return and notification of filer manual provides guidance on how to file a TIR or a Notification of Filer which is required in cases where the TIR has been filed in another jurisdiction and will be exchanged with Revenue. ROS access and upload instructions, links to the OECD’s detailed guidance and Revenue contact details are also included in the guidance.
Relevant ROS access and upload instructions together with other relevant return filing and payment obligations are outlined in the guidance on IIR, UTPR and QDTT Returns and Payments.
Prior to filing a return or making a payment, it is recommended that an entity should ensure their relevant Pillar Two registration is correct and up to date. In addition, where the constituent entities of a multinational or large-scale domestic group elect to form a QDTT group or a UTPR group, the members of the group should ensure that a group filer is appointed and that group filer completes the creation of the group on ROS.
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