Budget 2027 announcements. Implementation dates vary. · By K Imports

Budget 2027: Pillar Two safe harbours and administration

Ireland's announced implementation of the OECD Side-by-Side package and further guidance.

Sources checked 2026-10-07.

Who it affects and when

Audience: Groups and tax teams within the scope of Ireland's Pillar Two rules.

Timing: Implementation within the OECD agreement's required timeframes through the Finance Bill.

Safe harbours: Amendments cover extension of the Transitional Country-by-Country Reporting Safe Harbour and the Simplified Effective Tax Rate, Substance-based Tax Incentive, Ultimate Parent Entity and Side-by-Side Safe Harbours.
Administration: The legislation also reflects OECD Administrative Guidance published in May and September 2026 and updates penalty and filing provisions.

Check whether the group is in scope before considering safe-harbour eligibility.
Map the relevant jurisdiction, entity and accounting-period requirements.
Use the actual Irish provisions and OECD guidance; a Budget heading is not a standalone eligibility test.