Council Directive (EU) 2025/872 of 14 April 2025 amending Directive 2011/16/EU on administrative cooperation in the field of taxation (DAC 9) has been published in the Official Journal of the European Union of May 6, 2025. The Directive will enter into force on May 7, 2025. Consequently Member States will have to adopt and publish by December 31, 2025 the laws, regulations and administrative provisions necessary to comply with this directive. The first top-up tax reporting is due by June 30, 2026. Countries opting to delay the implementation of the Pillar 2 Directive are still required to transpose DAC 9 by the same deadline.
the DAC9 Directive was adopted by the Council of the European Union (Hereinafter: the Council) On April 14, 2025. The adopted Directive further amendments Directive 2011/16/EU on administrative cooperation in the field of taxation. The objective of the DAC9 directive is to put into operation specific provisions of the Pillar 2 Directive (Council Directive (EU) 2022/2523 of December 15, 2022) that implemented in the EU the G20/OECD global agreement on international tax reform.
DAC9 complements the Pillar 2 Directive (Directive (EU) 2022/2523) by streamlining filing obligations for multinational enterprise groups (MNEs) that are within its scope. DAC9 introduces a centralised framework for the exchange of the information contained in those filings. In doing so, DAC9 brings about significant simplification for business, as it enables MNEs to file only one Top-up Tax Information Return (TTIR), at central level, for the entire group, as opposed to multiple filing being made by each constituent entity of the MNE group, at local level.
The DAC9 Directive also introduces a standard form for filing the TTIR across the EU, in line with the one developed by the G20/OECD's Inclusive Framework on Base Erosion and Profit Shifting (BEPS).
Furthermore the DAC9 Directive also extends the framework for automatic exchange between member states to cover TTIR.
The text of Council Directive (EU) 2025/872 of 14 April 2025 amending Directive 2011/16/EU on administrative cooperation in the field of taxation (DAC 9) as published in the Official Journal of the European Union of May 6, 2025 can be found here.
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