Ireland updates Pillar Two TIR correction and exchange-code guidance

On 5 November 2026, Irish Revenue published eBrief No. 164/26 and an updated Tax and Duty Manual Part 04A-10-02. The update adds operational rules for correcting or deleting an accepted Top-up Tax Information Return (TIR), Ireland’s local GIR-equivalent return, and for coding the jurisdictions entitled to receive centrally filed information.

This is administrative guidance, rather than an amendment to Part 4A of the Taxes Consolidation Act 1997. It does not change the existing 15-month filing deadline or the 18-month deadline for a transition year.

Accepted returns use the correction route

Section 5.8 of the manual states that an accepted TIR must be corrected or deleted using MessageTypeIndic = GIR102. A file rejected by Revenue, or never uploaded, does not require that correction or deletion process. If two initial returns have both been accepted for the same period, the duplicate should be deleted.

The correction must link back to the prior valid data through CorrDocRefID. Revenue distinguishes this from simply replacing an entire return: the XML identifiers must preserve the chain between the accepted data and the correcting or deleting record.

New elements require deletion and a fresh initial return

The manual does not permit a correction message to add an element that was missing from the accepted return. Where new information must be introduced, the filer should delete the original return and submit a new initial return using DocTypeIndic = OECD1. Adding a new element through a correction triggers severe validation error 60004 and causes the file to be rejected.

Recipient codes control the exchange route

Section 5.9.4 explains that RecJurCode determines which jurisdictions receive each relevant part of a centrally filed return. An Irish local filing must include IE in every recipient-code field. Where Ireland is the central filing jurisdiction, each XML section must include every jurisdiction entitled to that information.

An omitted or incorrect code can prevent Revenue from transmitting the relevant section. That failure can result in another jurisdiction requesting a local TIR even though the group believed it had relied on central filing. The new guidance therefore turns recipient-code mapping into a substantive exchange control, not a purely technical field.