On 14 April 2025, the Council has adopted a further amendment of Directive 2011/16/EU on administrative cooperation in the field of taxation (DAC9).
The amendment will streamline filing obligation and reduce compliance burden for companies under the Pillar 2 Directive.
Today, the Council has adopted a further amendment of Directive 2011/16/EU on administrative co-operation in the field of taxation (DAC9), less than six months after the Commission presented its proposal and following the opinions of the European Parliament and the European Economic and Social Committee.
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, 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. This simplification is largely expected to be the main tool used by MNEs to comply with their filing obligations under the Pillar 2 Directive. DAC9 is therefore highly welcome in the context of the ongoing Commission’s efforts to rationalize reporting obligations and to reduce burden on EU businesses.
The rapid adoption of DAC9 emphasises the strong commitment of all member states to ensuring the seamless implementation of Pillar 2.
Next steps
Member States need to implement the directive into national legislation by 31 December 2025. MNEs are expected to file their first top-up tax information return by 30 June 2026, as required under the Pillar 2 Directive. The relevant tax authorities must exchange this information with each other by 31 December 2026 at the latest.
