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.

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