Tax Update
As at 31 May 2026
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Irish Revenue Commissioners Annual Report 2025 – key insights
Spotlight on APAs and MAP
The Irish Revenue Commissioners 2025 Annual Report (the “Report”) reveals record levels of APAs and MAP activity, alongside expanding exchange of information initiatives. Our team examines the key findings and what they mean for multinational enterprises operating in Ireland in our insight (here).
Next-level compliance
The Report also reveals a tax authority that is increasingly data-driven, technologically sophisticated and firmly focused on enforcement, with 237,550 audit and compliance interventions completed in 2025 yielding €734 million, a growing pipeline of tax avoidance cases and significant transfer pricing activity.
Revenue is also deploying advanced data analytics and AI-assisted tools to sharpen its risk identification capabilities. Our team has considered the key highlights on audit and compliance activity and what the report means for Irish taxpayers (here).
Status of the Finance (Tax Appeals and Fiscal Responsibility) Bill 2024
On 8 May 2026, the Joint Oireachtas Committee on Finance, Public Expenditure, Public Services Reform, Digitalisation and Taoiseach (the "Committee") published a report (here) following its pre-legislative scrutiny of the proposed reforms to the Tax Appeals Commission (“TAC”) under the Finance (Tax Appeals and Fiscal Responsibility) Bill 2024 (the “Bill”). The proposal that has garnered most attention throughout the process has been the proposal to hear tax appeals in public. Under the existing procedure, taxpayers that apply to have their hearing in private are automatically entitled to a private hearing.
Primary recommendation
The Committee's primary recommendation is that no changes be made to the current procedures for private and public hearings at the TAC.
The Committee's findings were strongly critical of the proposed reforms. Drawing on advice from the Office of Parliamentary Legal Advisers and submissions from external stakeholders, the Committee concluded that the tax appeal system does not need to be reformed and that, if implemented as currently drafted, the proposals would have a significantly negative impact on taxpayers' willingness to seek independent review of Revenue decisions and assessments.
The Committee also recommended that the Minister assess whether the proposed changes would render Ireland's tax system more punitive compared to European peers, with potential adverse consequences for foreign direct investment.
Secondary recommendations
Should the primary recommendation not be accepted, the Committee put forward the following alternative recommendations:
- Clearer criteria for private hearings: The legislation should include detailed, objective criteria to guide TAC Commissioners when deciding whether to grant a private hearing, with clear standards to ensure consistent application across Commissioners.
- Refined definition of “public”: Consider defining “public” in a manner that still protects taxpayer privacy (for example, by permitting journalists to attend hearings while requiring that any reporting be anonymised).
- Alternative dispute resolution: An ADR process which is capable of being conducted in private should be introduced as a preliminary step before recourse to the TAC.
- Privacy rights assessment: An assessment should be carried out as to whether the publication of appellants' details by Commissioners would constitute a proportionate interference with their privacy rights.
Next steps
It is widely anticipated that the Department of Finance will engage further with the Office of the Attorney General to determine how best to progress the draft legislation in light of the Committee's recommendations.
New Pillar Two Guidance issued by OECD
On 16 May 2026, the OECD issued two Pillar Two related documents, both designed to ease Pillar Two compliance for in-scope groups.
Global Information Return filing deadline - practical relief
The first document addresses two practical challenges ahead of the upcoming Global Information Return ("GIR") filing deadline:
- A number of jurisdictions that have enacted Pillar Two legislation may not have their filing portals ready in time; and
- Many of the bilateral agreements that would allow jurisdictions to exchange GIRs have not yet been activated.
The following relief measures have been agreed to address these issues:
Penalty waivers: Jurisdictions that do not have filing portals available have agreed to waive penalties to the extent permitted under local law (this aspect is not relevant for Ireland).
Exchange network relief: Where a GIR exchange agreement has not been activated by the filing deadline, jurisdictions will not enforce their local GIR filing requirements, provided that:
- The GIR has been filed centrally and on time in one jurisdiction; and
- A GIR notification has been submitted in each other relevant jurisdiction.
The expectation is that all necessary exchange agreements will be activated before year end, at which point GIRs will be shared between jurisdictions automatically.
Administrative guidance – 53 week financial year
The second document is additional guidance for in-scope groups with a floating year end that can result in a 53 week financial year.
The guidance confirms that groups with a 53 week financial year beginning on or before 31 December 2025 may continue to avail of the Transitional UTPR Safe Harbour for that year notwithstanding that it exceeds 12 months, provided that the following year qualifies for either the (i) Side-by-side Safe Harbour; or (ii) UPE Safe Harbour.
EU makes progress in approval of EU/US trade deal
Over the past few months, the EU has been internally negotiating the regulations that will implement the EU/US trade agreement. The process has been slowed by various unexpected tariff announcements made by the US. In response, the European Parliament has worked to incorporate safeguards into the EU implementation of the deal in the form of suspension provisions and a sunset clause.
The implementing regulations will authorise the European Commission to suspend the EU/US trade agreement if, for example, the US fails to meet its commitments under the agreement. The Commission is also empowered to suspend certain concessions if the US continues to apply a tariff rate exceeding 15% to EU steel and aluminium derivative products.
Under a sunset clause, the regulations will cease to apply at the end of 2029 unless they are extended.
The European Parliament is expected to vote on the regulations on 16 or 17 June.
Tax Controversy and Dispute Resolution updates
Tax Appeals Commission Annual Report 2025
The Tax Appeals Commission (“TAC”) has issued its Annual Report for 2025. It includes data on the number of appeals received and closed by the TAC in 2025. Some highlights include:
- The TAC closed 1,286 appeals in 2025 (that included 239 determinations and 464 settled cases) with a quantum of €605 million. Of that quantum, €423 million was attributed to cases that were settled.
- The increasing complexity of appeals over multiple tax heads and referencing European law continued to be a trend in 2025. This trend also resulted in a lower number of TAC hearings being scheduled (237 in 2025 which is expected to reduce to 180 in 2026).
- Corporation tax remains the tax head that involves the highest quantum cases (€423 million of the €605 million resolved in 2025 cases related to corporation tax appeals).
Legal Privilege in a Tax Context – A Practical Playbook
In this Insight, our team consider legal advice and litigation privilege in Ireland, key distinctions from other regimes and practical steps businesses can take to preserve privilege in tax controversy matters.
Matheson Tax insights
Increased Publicity on MNE Taxes
In this Insight, our team examines EU public CbC reporting, recent media attention on MNE taxes and the practical steps businesses should take to prepare for increased tax transparency and to ensure compliance with EU and Irish rules.
