Irish Revenue open Pillar Two Hub - What you need to know

Background

On 15 August 2025, Irish Revenue opened the Pillar Two Hub providing an overview of the relevant registration, filing and payment obligations for in scope groups. 

Upcoming registration obligations 

Registration obligations apply to: 

• Any entity that is subject to the Income Inclusion Rule (“IIR”) for a fiscal year;
• Any entity that is subject to the Undertaxed Profits Rule (“UTPR”) for a fiscal year; and
• Any qualifying entity for domestic top up tax (“QDTT”) purposes for a fiscal year.

It is expected that for most groups, registration will be completed on or before 31 December 2025. For in scope groups with a year end of 31 December 2024, the first filing of the IIR top up tax information return and filing and payment of the IIR and/or QDTT is expected to be due on or before 30 June 2026. Early engagement and planning of the Pillar Two compliance process will therefore be of importance for in scope groups. 

Information required on registration 

The information which must be supplied via ROS as part of making an Irish Pillar Two registration application includes: 

• Confirmation of the tax head or reporting obligation applicable (i.e. IIR top up tax, UTPR top up tax, Domestic top up tax and/or the Top up tax information return).
• Confirmation of the relevant entity type (i.e. ultimate parent entity (“UPE”) or constituent entity i.e. non UPE).
• Confirmation of whether the entity is part of a multi parented MNE or large-scale domestic group.
• The first fiscal year the group or standalone entity is in scope for Pillar Two.
• The role of the entity in filing the top up tax information return (i.e. whether the entity will file itself or whether filing will be carried on by a designated local entity or a designated entity in another jurisdiction). 
• Whether the entity wishes to elect to become part of a UTPR group and whether the entity is the UTPR group filer (where applicable).  
• Whether the entity wishes to become part of a QDTT group and whether the entity is the QDTT group filer. 

At present, the current registration facility available on ROS would suggest that registration is only possible on an entity-by-entity basis. As noted in communications issued by Revenue to potentially in scope companies, guidance on the registration process will be issued in due course. We will continue to monitor any developments in this regard.  

Our perspective and recommended action for in-scope groups

The release of the Pillar Two Hub follows an exercise carried out by Irish Revenue involving a review of their records, including Country by Country Reporting data, to identify groups that are expected to be in scope for Irish Pillar Two purposes in respect of 2024. We also understand that Irish Revenue have issued a communication to groups with an Irish ultimate parent entity (“UPE”) that have been identified as potentially in scope, reminding them of their registration requirements and requesting that, to the extent such groups are not considered to be in scope, they should notify Irish Revenue via MyEnquiries clearly outlining the basis upon which they are not considered to be within scope of the Irish Pillar Two rules for 2024. In this communication they have also outlined the applicable penalties for failing to meet the Irish Pillar Two registration requirements. 

This is expected to be the first wave of such communications to in scope groups, with further communication from Irish Revenue anticipated over the coming weeks and months to other groups and/or entities potentially falling within the scope of the Irish Pillar Two rules and related registration requirements.

While registration for most groups is required to completed by 31 December 2025, in scope groups should act now to ensure that registration obligations are complete. In particular, the requirement to give notice of an election to become a member of a QDTT group and the identification of the QDTT filer will need to be given early consideration. Where a QDTT group filer is identified, this entity takes on the filing and payment obligations for all QDTT group members; in scope groups should therefore consider in advance the role of the QDTT filer, and the potential associated compliance burden to be adopted in such a case. 

From an initial review of the registration portal on ROS it would appear that Irish Pillar Two registrations will need to be completed on an entity-by-entity basis. We await further guidance from Irish Revenue on this point and, in particular, whether a group registration will be possible (similar to what is possible in certain other implementing jurisdictions). 

Also of note are the applicable penalties of €10,000 for failure to complete the Irish Pillar Two registration on time. 

We welcome the comments from Irish Revenue that further guidance will be forthcoming around the Irish Pillar Two registration requirements along with the update that the filing and payment of Irish Pillar Two returns and associated liabilities is expected to be possible via ROS from early 2026 (ahead of the filing deadline for 2024 of 30 June 2026). We strongly recommend that in scope groups accelerate their Pillar Two compliance preparations with a view to being ready to complete the necessary filings by the end of the year – this approach will allow time to address any local country nuances that will inevitably arise given the complexity associated with Pillar Two and the manner in which it has been implemented in different countries. This acceleration in Pillar Two compliance preparation may very well be necessary in any event given the deadline introduced in Belgium for Pillar Two returns of 30 November 2024 and other accelerated deadlines which may be introduced in other countries for either the filing of Pillar Two returns or the making of payment on account for anticipated Pillar Two liabilities; or potentially both.   

Should you have any queries on the above please do not hesitate to reach out to your regular Deloitte contact who will be able to support you to the extent required with the completion of your Irish Pillar Two registration requirements.