Ireland Extends Pillar 2 Registration Deadline

Amended Section 111AAH of the Finance Act 2024 provides that the registration date is December 31, 2025, where the registration date is earlier than 31 December 2025.

On December 18, 2025, the Irish Revenue issued Revenue eBrief No. 244/25 which provides for an extension in the Pillar 2 registration deadline to February 29, 2026 (from December 31, 2025).

Section 111AAH of the Law provides that an Irish entity subject to top-up tax (either under the IIR or UTPR) is required to notify the tax authority within 12 months from the the last day of the first fiscal year during which it is a relevant parent entity, immediately following a fiscal year for which it was not a relevant parent entity.

The registration is a “once off” registration (i.e. it would not be required annually).

There will also be a requirement to de-register when a Constituent Entity falls out of scope of the GloBE rules. The deadline for this will be 12 months after the end of the first Fiscal Year in which the entity is no longer in scope.

The information to be provided at registration is:

-Name of the Constituent Entity.

-Tax reference number of the Constituent Entity.

-The name of the MNE group.

-The Ultimate Parent Entity of the group and its location as per the GloBE rules.

-If appropriate, the Designated Filing Entity and its location.

-A local contact person.

-The first Fiscal Year for which the group is in scope.

-The date on which the accounting period of the group normally ends.

-If appropriate, the name and tax reference number of the Designated Local Entity, including confirmation that it has been nominated by the other Constituent Entities to act as such.

-If a Designated Local Entity, the names and tax reference numbers of the Constituent Entities for which it has been appointed the Designated Local Entity and confirmation that it has been nominated by the Constituent Entities to act as such.