Multinational Corporation Tax: Pillar Two Administrative Obligations

BDO Ireland
Insights
2026
Multinational Corporation Tax: Pillar Two Administrative Obligations

Multinational Corporation Tax: Pillar Two Administrative Obligations

Pillar Two is a new global tax framework designed to ensure large multinational groups pay at least 15% tax in every jurisdiction where they operate. The Pillar Two rules came into effect in Ireland for accounting periods commencing on or after 31 December 2023 and applies to Large MNE groups or domestic groups with a consolidated annual group revenue of at least €750M in at least two of the immediately preceding four fiscal years.

In scope groups must file a GloBE information return within 15 months of the year end. However, for the first year an entity is in scope the filing deadline will be extended to 18 months post year end.

All Irish constituent entities must register with Revenue within 12 months of the last day of the first fiscal year during which the entity is in scope, i.e. any Irish entities that become subject to the Pillar Two rules for the accounting period ended 31 December 2024 will be required to register by 31 December 2025.

An entity must register where it is one of the following types of Pillar Two entities:

Relevant parent entity: subject to the income inclusion rule (IIR) top-up tax
Relevant under-taxed profits rule (UTPR) entity: subject to UTPR top-up tax
Qualifying entity: subject to domestic top-up tax

A relevant parent entity is an entity that is required to collect Pillar Two top-up tax via IIR. IIR is collected by the ultimate parent entity (UPE) or, if the UPE is not required to apply IIR, an intermediary parent entity (IPE) may apply IIR.

A relevant UTPR entity is an entity that is required to collect Pillar Two top-up taxes via UTPR. An entity may be required to apply UTPR where the UPE is not required to apply IIR to its subsidiaries.

All in-scope Irish entities will be considered qualifying entities.

In December, Revenue released additional guidance to extend the deadline for registration where the original registration deadline was on or before 31 December 2025; the registration deadline has been extended to 28 February 2026.

The updated guidance also provided clarification on the registration requirements for dormant / inactive entities and dissolved entities.

Revenue is prepared to accept that inactive/dormant entities are not required to register for Pillar Two in Ireland, subject to the following requirements being satisfied:

An entity that is incorporated and never traded or held any assets; or
An entity that had income and/or assets in the past and is now inactive, but remains within
the group

In order to avail of the exemption, the entity must contact Revenue in advance of the registration deadline.

A dissolved entity cannot complete the registration process on ROS. Accordingly, the filing entity or the UPE should ensure that the dissolved entity’s details are included in the return filed on behalf of the group.

As both the registration deadline and the return filing deadline are quickly approaching, we would recommend that in scope groups and groups who are not certain of their Pillar Two exposure, assess their Pillar Two position now.

Content adapted from DCU Business School.