On 14 August 2025, the Irish tax authorities (Irish Revenue) launched their Pillar Two Hub—a dedicated website for updates and guidance on Ireland’s implementation of the global minimum tax—along with a new online registration platform. The Hub is now available at Irish Revenue’s Pillar Two page.
The Global Context
Pillar Two introduces a 15% minimum effective tax rate for large multinational and certain large domestic groups. The regime is designed to limit profit shifting to low-tax jurisdictions and is enforced through a series of interlocking rules.
- The Income Inclusion Rule (IIR) charges a top-up tax at the parent company level if a group’s subsidiaries are taxed below the minimum.
- The Qualified Domestic Top-Up Tax (QDTT) allows a country to collect the additional tax domestically, rather than ceding it to another jurisdiction.
- The Undertaxed Profits Rule (UTPR) acts as a final backstop. It reallocates profits across group entities if the minimum tax has not been fully collected elsewhere.
For groups with complex international footprints, these rules interact in ways that can significantly change effective tax outcomes.
Registration Requirements
The new Irish platform requires certain groups to register their in-scope entities. The threshold is set at €750 million of consolidated revenues in at least two of the preceding four fiscal years. Both multinational and large domestic groups fall within this net.
Importantly, the scope is not limited to traditional companies. Entities that prepare standalone financial statements, such as partnerships or contractual funds, can also be required to register even if they are tax-transparent.
The registration obligation applies to entities subject to IIR, UTPR, or QDTT in respect of fiscal years beginning on or after 31 December 2023. For groups with a December year-end, this means that the first deadline falls on 31 December 2025.
Information to be Disclosed
When registering, an entity must provide:
- Basic corporate information, including name and Irish tax identification number.
- The rules under which it is in scope, and the first fiscal year of application.
- Details of the ultimate parent entity, including its location and identification number.
- The role of each entity within the group, such as designated local entity or filing entity.
- Whether the entity belongs to, or intends to form, a QDTT or UTPR group, and if so, which entity will act as the filer.
Revenue is also proactively contacting certain groups, particularly those with Irish parent entities, based on existing reporting data. In some cases, groups may be asked to confirm that they fall outside the regime if registration is not required.
Deadlines and Penalties
The key deadline for registration is 31 December 2025. Missing this date may result in financial penalties of up to €10,000. The obligation applies regardless of whether a top-up tax liability actually arises.
While registration is already available, the ability to file returns and make payments will only come online in early 2026. The first filings, covering fiscal year 2024 for calendar-year groups, will be due by 30 June 2026.
Exchange of Information
A new layer of transparency accompanies these rules. Within the European Union, tax authorities are required to exchange information on Pillar Two filings. This exchange will take place automatically, ensuring that each member state has visibility on the global activities of in-scope groups.
The first exchange will occur by the end of 2026 for fiscal years beginning in 2024. Thereafter, exchanges will take place within three months of the filing deadline.
Practical Considerations for Tax Professionals
Tax teams and investors should begin preparing immediately. Key priorities include:
- Scoping the group – confirming which entities fall under the regime and which rules apply.
- Data collection – gathering the necessary information on ownership, fiscal years, and designated roles.
- Workflow design – planning how the group will handle filings, payments, and monitoring across multiple jurisdictions.
- Technology – assessing whether internal systems are capable of handling complex global minimum tax calculations or if specialist tools are needed.
- Transfer pricing alignment – reviewing current policies to identify areas where Pillar Two may affect outcomes.
Even groups that ultimately face little or no additional tax must register and prepare to report. The operational burden of Pillar Two is significant and requires early planning.
Conclusion
Ireland’s launch of its Pillar Two Hub and registration platform marks the beginning of a new compliance era. The rules are wide-ranging, the deadlines are firm, and the penalties are real. For multinational groups, the challenge is not only technical but also operational.
By scoping entities, registering on time, and investing in systems now, tax professionals and investors can position their organizations to manage this global minimum tax regime with confidence.
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