Irish Revenue has published new guidance covering the filing of Top-up Tax Information Returns (TIRs) under Pillar Two, alongside a separate manual outlining filing and payment obligations for Income Inclusion Rule (IIR), Undertaxed Profits Rule (UTPR) and Qualified Domestic Top-up Tax (QDTT) returns.
Irish Revenue has released two new eBriefs providing operational guidance for entities subject to the OECD’s Pillar Two global minimum tax framework, including instructions for filing information returns and meeting tax return and payment obligations.
Guidance on top-up tax information returns
Revenue eBrief No. 106/26, issued on 26 May 2026, introduces a new manual titled Top-up tax information return and notification of filer – user guide. The manual is intended for entities within the scope of Pillar Two that are required to file a Top-up Tax Information Return (TIR).
The TIR is Ireland’s term for the GloBE Information Return (GIR) under the OECD’s Pillar Two Model Rules and is also referred to as the DAC9 return under the relevant EU directive. The return contains the Pillar Two information that must be reported in a standardised format.
The guidance explains the procedures for filing a TIR and for submitting a Notification of Filer (NoF), which applies where the return is filed in another jurisdiction by a group’s ultimate parent entity or another designated filing entity and the information is subsequently exchanged with Irish Revenue.
The manual applies to all entities within the scope of Pillar Two, including multinational enterprise groups, large-scale domestic groups, standalone entities and their agents.
Among the topics covered are access and upload procedures through Revenue Online Service (ROS), links to and extracts from OECD guidance on the standardised return format and XML validation requirements, and Revenue contact details for taxpayers and advisers.
Revenue noted that the TIR has been available for filing since the end of April 2026.
New manual on IIR, UTPR and QDTT obligations
In a separate publication, Revenue eBrief No. 107/26 introduces Tax and Duty Manual Part 04A-10-03, a new guidance document created in May 2026 covering filing and payment obligations for returns under the Income Inclusion Rule (IIR), Undertaxed Profits Rule (UTPR) and Qualified Domestic Top-up Tax (QDTT).
The manual outlines the processes that entities must follow when filing returns and making payments under Ireland’s Pillar Two regime.
Revenue emphasised that entities should ensure their Pillar Two registrations are accurate and up to date before submitting returns or making payments.
The guidance also addresses group filing arrangements. Where constituent entities of a multinational enterprise group or large-scale domestic group elect to form a QDTT group or a UTPR group, members must appoint a group filer. The appointed filer is responsible for creating the group within ROS and managing the relevant filing obligations.
