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Ireland's 15% rate for large groups sits beside the 12.5% trading rate

Ireland applies Pillar Two to groups with EUR 750 million or more in revenue; everyone else keeps 12.5% on trading income.

Where
EU ↔ UK · India ↔ UK & EU · US ↔ EU · Ireland
Published
Last reviewed
Prepared
Prepared by the Intelligence desk with AI-assisted research from the cited sources, checked on 12 November 2026.
Effective
1 January 2024
Version
1

What changed

Ireland taxes trading income at 12.5% and non-trading income at 25%. It legislated the Pillar Two rules with effect from 1 January 2024 for the Income Inclusion Rule and the Qualified Domestic Top-up Tax, and from 1 January 2025 for the Undertaxed Profits Rule. In-scope groups, with consolidated revenue of EUR 750 million or more in at least two of the four preceding years, pay at least a 15% effective rate in Ireland.

Who is affected

Large multinational groups with Irish operations; companies comparing Ireland with the UK or other EU locations for an EU base.

Why it matters

For most companies the 12.5% rate remains, so the gap with the UK's 25% main rate is large. For large groups the effective floor is 15%, and the choice rests more on EU market access, talent and substance. The UK vs Ireland Decision Map sets these side by side.

What to examine next

Check which rate applies to each income stream (trading or non-trading).
Confirm whether the group is in scope of Pillar Two.
Compare UK and Irish bases in the UK vs Ireland Decision Map.

Sources

  1. Ireland: Taxes on corporate incomePwC Worldwide Tax Summaries · checked 12 Nov 2026 · secondary source
  2. Ireland Highlights 2024Deloitte · published 12 Nov 2026 · checked 12 Nov 2026 · secondary source

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Original analysis by the UNBOUNDED Intelligence desk. Linked sources belong to their publishers. This briefing is information, not legal, tax, investment or other professional advice. Its appearance here is not an endorsement by UNBOUNDED or any institution of a transaction, jurisdiction, strategy or counterparty.