Edwina Hilton, Tax Associate, Ogier: The most recent Exchequer Returns (published 11 May 2026) strike an encouraging note: on a like-for-like basis, tax receipts were up 4.2% to end-April 2026, with corporation tax at €3.46 billion - an increase of €0.28 billion (+8.6%) year on year (with figures excluding the tax revenues associated with the Court of Justice of the European Union (CJEU) 2024 ruling (i.e. the Apple case windfall)). That said, it is important to emphasise that Q1 and April are not typically significant corporation tax months, with the major payment dates still to come. While these figures provide a positive early signal, in a period of continued global uncertainty - as repeatedly highlighted by the Department of Finance - we would caution against drawing definitive conclusions about the full-year outlook as the underlying trends will only become clearer as the year proceeds.

On the international tax front, the EU minimum tax regime (Pillar Two) has now moved from legislative concept to operational reality. The registration deadline for in-scope multinational groups expired on 28 February, and first returns and payments are expected from June onwards. While there were early concerns about a potential mass exodus of large international MNEs, there is, so far, no concrete evidence to support those fears. However, taxpayer confidentiality necessarily restricts visibility: it is not possible to know exactly which groups have registered or if any have exited or downsized their operations. The prevailing consensus suggests that a dramatic departure has not occurred, but, as ever, longer-term trends can only be assessed with time and broader economic data.

Beneath these headline figures lies the more fundamental - and persistent - challenge of concentration risk. Revenue’s 2025 statistics reveal that just ten companies accounted for 56% of net corporation tax paid, and foreign-owned multinationals contributed 87%. This small cohort not only underpins the corporation tax base, but also generates significant high-value employment and, by extension, a substantial share of income tax yields. While Pillar Two may increase the effective tax paid by some groups, it does not diminish the State’s underlying exposure: such reliance can flatter receipts in robust years but leaves public finances highly sensitive to sectoral fortunes and corporate structural shifts. The Government’s ongoing commitment to building fiscal buffers - through transfers now approaching €20 billion to the Future Ireland Fund and the Infrastructure, Climate and Nature Fund - is prudent.

Nonetheless, strong receipts in 2026, welcome as they are, cannot resolve a longstanding policy question: is Ireland’s structural reliance on a narrow group of large taxpayers - and their employees - a balanced and sustainable foundation for the medium term? Calls to diversify the tax base have been a recurring theme in Irish fiscal commentary, and in our view, remain more pertinent than ever as the global tax landscape continues to evolve.

Deirdre Barnicle, Partner, McCann FitzGerald: Irish corporation tax receipts for April 2026 were notably strong at €564 million. This comes alongside warning calls from IFAC that reiterate Ireland’s continued critical dependence on corporation tax receipts from a small number of companies. The Governor of the Central Bank of Ireland flagged his concern that Ireland needs to urgently find additional sources of revenue to alleviate its reliance on US FDI in light of the increasing threats of greater tariffs. This is not yet reflected in the corporation tax receipts mainly on account of the largest MNEs in Ireland (e.g. Eli Lilly, which exports weight loss drugs) entering into bilateral tariff-free trade deals with the US government in return for investments in US manufacturing.

However, the Governor stressed that this is a short-term position, and these receipts should no longer be assumed into the future. There are positive indications, and the corporation tax base does appear to be broadening, with the analysis by the Revenue Commissioners noting that net corporation tax receipts from smaller and medium sized companies grew by 15% in 2025. A lot more will be revealed by the corporation tax receipts in May and June, which will be impacted more closely by the supply chain disruption and energy crisis in the Middle East. Smaller companies are less insulated from the impact of these difficult operating environments, which could serve to quell this positive trend.

This article appeared in the May 2026 edition of the Irish Tax Monitor.