Revenue updated its Pillar 2 registration guidance, extending the registration deadline for certain in-scope entities and clarifying administrative practices for specific entity scenarios.
Irish Revenue has issued Revenue eBrief No. 244/25 on 18 December 2025, announcing updates to Tax and Duty Manual Part 04A-01-01A (Guidance on Pillar 2– Registration), including an extension to the Pillar 2 tax registration deadline for certain in-scope entities.
Under the update, for in-scope entities whose first fiscal year ends in 2024, the Pillar 2 tax registration deadline has been extended to 28 February 2026, from 31 December 2025, as set out in paragraph 2.2 of the manual.
The revised guidance also introduces several administrative clarifications. A new paragraph 2.1.1 details a new Revenue administrative practice for inactive or dormant entities that meet specific conditions.
Paragraph 2.1.2 sets out Revenue’s administrative practice where there is a dissolved entity within a multinational enterprise (MNE) group, while paragraph 2.1.3 provides guidance on the registration process for entities that do not have an active tax registration.
In addition, paragraph 2.5.1 has been updated to clarify the ROS permissions required for users operating under a ROS sub-user certificate. Paragraph 4.1.4 has been removed, reflecting that the amended fiscal year function is no longer available. Appendix E has also been updated to include guidance on approving agent link requests within 30 days and to outline requirements for an MNE group registering using its own TAIN DigiCert.
Earlier, Irish Revenue released eBrief No. 170/25 on Tax and Duty Manual Part 04A-01-01A on 5 September 2025, providing comprehensive guidance on the registration process for Pillar 2 taxes.
