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Pillar Two

Ireland · Administrative guidance

Ireland updates Pillar Two return correction and exchange-code guidance

Published 2 min read

On 5 November 2026, Irish Revenue issued eBrief No. 164/26 and updated Tax and Duty Manual Part 04A-10-02, adding operational rules for correcting or deleting Pillar Two Top-up Tax Information Return XML files and for assigning recipient-jurisdiction codes when returns are centrally exchanged.

Official document:
Revenue eBrief No. 164/26; Tax and Duty Manual Part 04A-10-02
Development date:
2026-11-05

Correct accepted returns through the XML chain

Where Revenue Online Service has accepted a TIR, a filer should not simply upload another initial return for the same fiscal period. The updated manual requires a GIR102 correction or deletion message, using OECD2 for corrected data or OECD3 for deleted data and linking the replacement record to the latest accepted record through CorrDocRefID. If the original XML never uploaded or failed full schema validation, it was not accepted and does not need a correction or deletion message.[2]

A correction cannot add a new element that was absent from the original return. Revenue says the original submission must instead be deleted and a new OECD1 initial message filed; adding a new element to a correction or deletion triggers severe error 60004 and rejection. For the first filing year, a correction that does not alter top-up tax, an election or a safe-harbour claim will be treated as filed on time where the original return was timely. A post-deadline change to an election or safe harbour requires contact with Revenue and case-specific consideration.[2]

Exchange codes determine where information goes

RecJurCode values control which jurisdictions receive each portion of a centrally filed TIR. For local Irish filing, IE must appear in each RecJurCode occurrence. For central filing in Ireland, each XML section must contain the jurisdictions entitled to receive it; an implementing jurisdiction’s code belongs in every Summary section, not only that jurisdiction’s own summary. FilingInfo should include all implementing and QDMTT-only jurisdictions. Missing or inconsistent codes may prevent exchange and lead the affected jurisdiction to require a local return.[1][2]

Controls for multinational groups

Irish constituent entities, designated local entities and filing agents should reconcile group entities, taxing-rights jurisdictions and active exchange relationships before generating XML. They should preserve original MessageRefID and DocRefID values, distinguish an accepted-with-errors ROS notice from a rejection, and avoid duplicate GIR101 submissions. The guidance changes correction and exchange mechanics; it does not change the statutory TIR or notification-of-filer deadline or calculate any group’s top-up tax.[2]

Groups should test RecJurCode population across FilingInfo, Summary, JurisdictionSection and UTPRAttribution, then route accepted-message errors through the prescribed correction chain. Entity scope, the correct recipient jurisdictions and any local-filing exposure remain fact-specific and must be verified for the reporting period.[2]

Official sources

  1. [1] Revenue eBrief No. 164/26

    Irish Revenue · Document date: 2026-11-05

    Dated heading and bullets covering sections 5.8 and 5.9.4 and Appendices B–D.

  2. [2] Tax and Duty Manual Part 04A-10-02 — Top-up tax information return and Notification of Filer user guide

    Irish Revenue · Document date: 2026-11-05

    Official 130-page PDF updated November 2026: pp. 1 and 6–12; sections 5.7.5–5.9.4 at printed pp. 18–24; Appendix C pp. 55–66; Appendix D pp. 67–68, especially correction/deletion and RecJurCode guidance.

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