On 28 August 2026, Irish Revenue published eBrief No. 125/26 providing further guidance on the implementation of the OECD/G20 Pillar Two Global Anti-Base Erosion (GloBE) rules in Ireland. The eBrief covers the Income Inclusion Rule (IIR), Undertaxed Profits Rule (UTPR), and Qualified Domestic Minimum Top-up Tax (QDMTT), which apply to multinational enterprise (MNE) groups with consolidated revenue exceeding €750 million. The guidance clarifies the computation of effective tax rates, the filing of Top-up Tax Information Returns, and the notification of the filing entity. It is effective for fiscal years starting on or after 31 December 2023.
Key Takeaways
- Filing Obligations: The Ultimate Parent Entity (UPE) or designated filing entity must submit a Top-up Tax Information Return and GloBE Information Return via ROS within 15 months of the fiscal year end (18 months for the first year).
- QDMTT Credit Mechanism: Ireland’s QDMTT ensures top-up tax is collected domestically first, reducing IIR liability elsewhere. The eBrief details the credit calculation and carry-forward rules.
- Transitional Safe Harbours: Guidance on the Temporary CbCR Safe Harbour, the Simplified Calculations Safe Harbour, and the De Minimis Exclusion, which may reduce compliance burden for qualifying groups.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement