Ireland has provided welcome but strategic breathing room for multinational groups navigating Pillar Two compliance. The Irish Revenue Commissioners have formally extended the Pillar Two registration deadline to 28 February 2026 for groups with a calendar-year fiscal period ending 31 December 2024.
While this extension eases immediate pressure, it does not reduce the underlying compliance expectations. From a Transfer Pricing perspective, this registration requirement is more than an administrative step — it is a signal event that brings group structures, profit allocation, and effective tax rate outcomes into sharper focus.
What Changed: Ireland Extends the Pillar Two Registration Deadline
Ireland has revised the deadline for Pillar Two registration following guidance issued in December 2025.
Key Facts at a Glance
- New registration deadline: 28 February 2026
- Previous deadline: 31 December 2025
- Who is affected: Groups with a fiscal year from 1 January to 31 December 2024
Nature of filing: One-time Pillar Two registration
The extension applies only to registration timing — it does not alter the scope of entities or the underlying Pillar Two obligations.
Why This Matters for Transfer Pricing in Ireland
Ireland is a jurisdiction where Transfer Pricing, Pillar Two, and statutory reporting are increasingly interconnected. Pillar Two registration provides Irish Revenue with early visibility into:
- Group structure and entity population
- Which entities are treated as in-scope
- How profits are allocated across jurisdictions
- Potential effective tax rate pressure points
Once registered, discrepancies between Transfer Pricing documentation, Master File disclosures, and Pillar Two calculations become easier to identify.
Strategic insight: Registration is the first data checkpoint — not the last.
Registration Is Mandatory Even If No Top-Up Tax Is Due
A critical point often misunderstood by groups:
Pillar Two registration is required even where no top-up tax arises.
Irish constituent entities must register if they fall within the scope of:
- Income Inclusion Rule (IIR)
- Undertaxed Profits Rule (UTPR)
- Ireland’s Qualified Domestic Top-Up Tax (QDTT)
This applies regardless of:
- High effective tax rates
- Loss-making positions
- Minimal local activity
Failure to register can create procedural exposure, even when no cash tax is payable.
Clarifications That Impact Group Compliance
Irish Revenue has also clarified how registration should be handled in non-standard scenarios — areas that frequently cause delays or errors.
Dormant, Inactive, or Dissolved Entities
Groups must still evaluate whether such entities:
- Fall within Pillar Two scope
- Require registration to preserve consistency
- Need disclosure to avoid gaps in group reporting
Ignoring inactive entities often leads to data mismatches during later reviews.
Entities Without Active Irish Tax Registration
International Joint Taxation
The updated rules provide clearer guidance on how jointly taxed entities are treated for Pillar Two purposes.
Why this matters:
- Incorrect treatment can distort effective tax rate (ETR) calculations
- Errors may cascade into top-up tax exposures
- Transfer Pricing assumptions may need recalibration where joint taxation alters profit attribution
Agent-Based Registration Is Permitted
Irish Revenue allows authorised agents to complete Pillar Two registration on behalf of entities via the Revenue Online System.
However, agent-led filing does not reduce responsibility — accuracy remains with the group.
The Transfer Pricing Risk Angle
From a Transfer Pricing standpoint, Pillar Two registration acts as an early-warning mechanism for tax authorities.
Once registration data is on file, Irish Revenue can:
- Cross-check entity roles against Transfer Pricing files
- Compare profit levels with Pillar Two ETR outcomes
- Identify inconsistencies across years and filings
Groups with legacy Transfer Pricing policies or outdated entity characterisations face heightened scrutiny.
What Multinational Groups Should
The deadline extension should be used strategically, not passively.
Recommended next steps:
- Confirm which Irish entities fall within Pillar Two scope
- Validate entity status (active, dormant, dissolved)
- Align Transfer Pricing outcomes with Pillar Two modelling
- Review Master File and Local File consistency
- Decide whether agent-led registration is appropriate
Early alignment significantly reduces downstream audit and remediation risk.
How TransferPricing.report Can Support Ireland-Focused Compliance
- Now is the right time to reassess your Denmark exposure. Smart next steps include:
- Validating entity identifiers across CbC, Transfer Pricing, and statutory filings
- Stress-testing Transfer Pricing policies against Pillar Two outcomes
- Reviewing joint taxation and securitization structures
- Ensuring deferred tax assumptions align across teams
- Updating documentation to reflect current operational reality
Early action reduces both audit risk and remediation cost.
Final Takeaway: The Deadline Moved, the Expectations Did Not
- Have Irish entities in your group?
- Unsure whether registration is required or already overdue?
Speak with our Transfer Pricing specialists today and turn this extension into a strategic advantage.
This is general information only and not professional advice. Consult a professional before acting.
