On Tuesday 11 March 2025 the EU Council reached a political agreement on the Directive on Administrative Cooperation in the field of taxation, also referred to as DAC9.
What is DAC9?
DAC9 updates the existing EU’s Directive on Administrative Cooperation (DAC) by expanding tax transparency rules. In particular, the update aims to simplify reporting for large groups in the context of Pillar Two (or the global minimum tax). Pillar Two includes a coordinated system of rules designed to ensure that large (domestic/MNE) groups, that have a consolidated revenue exceeding EUR 750 million for at least two of the four previous years, are subject to a minimum effective tax rate of 15%. For more information on this topic, refer to one of our previous news alerts.
In summary, DAC9 includes the following key items:
- Centralised filing: allowing multinational enterprise groups to file a single top-up tax information return for the entire group.
- Exchange mechanism between the tax authorities of the Member States: enabling tax authorities to share the relevant sections of the top-up tax information return or other required information.
- Top-up tax information return template: a standard template for the top-up tax information return. The objective is to ensure alignment with the GloBE Information Return (GIR) published by the OECD.
For more details, refer to PwC’s Tax Bites Podcast episode on the DAC9 proposal.
What are the next steps?
DAC9 will be formally adopted by the EU Council once the legal linguistic work has been completed. Afterwards, it will be published in the Official Journal and will enter into force on the day following its publication. All Member States will have to implement DAC9 by 31 December 2025 in their local legislation.
For more details on DAC9 and Pillar Two compliance requirements, reach out to your regular contact person or contact Pieter Deré, Evi Geerts or Maxim Allart.
Contact persons
Pieter Deré – Evi Geerts – Maxim Allart
Authors
More news about
- Accounting and Tax Compliance
- International taxation
- Tax challenges arising from the digitalisation of the economy/Global anti-base erosion (GloBE)
