Pillar Two in Ireland - What it means for your business in 2026
- 1 day ago
- 3 min read
Pillar Two is now part of the global tax landscape.
For many businesses, the focus has shifted from understanding the rules to meeting real deadlines.
If your business is part of a large multinational group, 2026 is an important year for compliance. What matters now is understanding whether your group is within scope, what the Irish filing process looks like, and where your local entity fits into the wider reporting picture.
What is Pillar Two?
Pillar Two introduces a 15% minimum effective tax rate for large multinational groups.
It applies to groups with annual revenues above €750 million. Where a group’s effective tax rate in a jurisdiction falls below 15%, a top-up tax may arise.
Ireland has implemented Pillar Two through rules including the:
Income Inclusion Rule
Undertaxed Profits Rule
Domestic top-up tax
The rules require complex calculations, new data points and coordination across multiple jurisdictions.
Why Irish entities still need to pay attention
Even where the wider group is leading the Pillar Two process, Irish entities may still be affected.
That is because the rules apply at group level, but local entities may still have responsibilities around registration, reporting, data collection and local compliance.
In-scope Irish entities can register for Pillar Two through ROS.
For Irish businesses that are part of an in-scope group, the key question is not just whether Pillar Two applies.
It is also whether the local entity understands its role in the process.
Key dates to know
For in-scope entities whose first fiscal year ended in 2024, the registration deadline was extended from 31 December 2025 to 28 February 2026.
For all other entities, the registration deadline is 12 months after the end of their first fiscal year.
The ROS system developments needed to allow return filing and payment of associated liabilities are now available in ROS, enabling entities to meet the 30 June 2026 pay and file deadline.
In addition, the ROS updates to file the top-up tax information return will be available in ROS before the 30 June 2026 filing deadline.
What businesses should be doing now
For businesses within scope, the focus should now be on readiness.
That means understanding whether the group is in scope, confirming who is responsible for the Pillar Two process, identifying what information may be needed from the Irish entity, and making sure local teams are aligned with the wider group timetable.
This is not an area to leave until the last minute.
Late filings and late payments can create additional exposures, including surcharges and interest.
A practical point for Irish businesses
For many Irish entities, Pillar Two will not be something they manage alone.
The detailed technical analysis, calculations and filing approach will often sit with the wider group tax function or with specialist advisers.
However, local finance and tax teams still need visibility.
They need to know what is happening, what is expected of them, and whether the right steps have been taken in Ireland.
Stay informed
Pillar Two is a highly technical area, and the compliance framework is continuing to develop.
At UHY Farrelly Dawe White, we are monitoring Irish Revenue guidance and key Irish filing developments so businesses can stay aware of what is changing and when action may be needed.
Businesses affected by Pillar Two should seek specialist advice to understand how the rules apply to their group and what filing obligations arise in practice.
