Revenue has published an update on Pillar Two filings with a reminder to in scope entities with an accounting period ended 31 December 2024 that tomorrow, Tuesday 30 June 2026 is the due date to file their Pillar Two information returns and/or their domestic tax returns and pay any associated Irish tax liabilities arising under Pillar Two.
Revenue has noted the strong compliance levels in advance of tomorrow’s deadline and to date, over 40 Top-up Tax Information Returns (TIRs), 700 Notification of Filer Returns (NoFs), and over 600 domestic returns across the Income Inclusion Rule (IIR), the Undertaxed Profit Rule (UTPR) and the Qualified Domestic Top-up Tax (QDMTT) have been filed.
Revenue has also published a user guide on the information returns, as well as an updated manual on the public filing interface itself. These materials provide further clarifications, including how Revenue will apply late‑filing penalties.
The user guide on the information returns has been 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. The PIT User Guide is also updated to include the new appendix on resolving errors.
In the update, Revenue notes that 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 notes 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, which is a date that is later than 18 months following the end of the fiscal year.
Revenue has confirmed that 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 in the following circumstances:
- a NoF has been submitted to Revenue on or before the specified return date, and
- 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
- the date to which penalties will not apply in that jurisdiction, and
- 30 September 2026.
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