Jurisdictions › Ireland
Enacted

Ireland Pillar Two

Europe

Effective
Jan 2024
IIR local name
IIR
QDMTT local name
Qualifying Domestic Top-up Tax (QDTT)
IIR
IIR
Enacted
UTPR
Not adopted
✕ Not adopted
QDMTT
Qualifying Domestic Top-up Tax (QDTT)
Enacted
In development — This profile is provided for reference only and may contain inaccuracies. Always verify against official legislation and current OECD guidance.
Key implementation point

UTPR deliberately excluded — Ireland does not tax undertaxed profits of foreign group members.

Implementation detail
  • 01 Ireland enacted Pillar Two as required by EU Directive 2022/2523, despite its 12.5% headline CT rate.
  • 02 QDTT (domestic top-up) ensures top-up tax is collected by Ireland rather than by another jurisdiction under IIR.
  • 03 UTPR not enacted — Ireland lobbied against UTPR, citing concerns for FDI competitiveness.
  • 04 Significant compliance burden for Ireland-headquartered MNEs: many large multinationals have their EMEA HQ in Ireland.
  • 05 Revenue (Irish tax authority) published Pillar Two guidance and stakeholder FAQs through 2024–2025.
  • 06 Ireland's effective CT rates for many multinationals were already above 15% once GloBE adjustments applied.
Enacted legislation Finance (No.2) Act 2023
Track Ireland rules against your live MNE

In Pillar2OS you can pull this jurisdiction's rules directly into your entity structure — automatically calculating top-up positions, flagging QDMTT obligations, and tracking rule changes as they happen across all your operating countries.

See it in the sandbox →