The Council of the European Union has reached a political agreement on a further amendment to Directive 2011/16/EU on administrative cooperation in taxation (DAC9). This decision comes just five months after the European Commission presented its proposal, following consultations with the European Parliament and the European Economic and Social Committee.
STREAMLINING FILING OBLIGATIONS UNDER PILLAR 2
DAC9 is designed to complement the Pillar 2 Directive (Directive (EU) 2022/2523) by streamlining the filing obligations for multinational enterprise groups (MNEs) that fall under its scope. The amendment introduces a centralized framework for the exchange of tax-related information, significantly reducing the compliance burden on businesses.
Under the new directive, MNEs will be able to submit a single top-up tax information return at a central level, rather than requiring multiple filings by each constituent entity at a local level. This simplification is expected to be the primary mechanism for ensuring MNE compliance with the Pillar 2 Directive.
COMMITMENT TO REDUCING ADMINISTRATIVE BURDENS
The swift adoption of DAC9 underscores the commitment of EU Member States to the smooth implementation of the Pillar 2 framework. The initiative aligns with the European Commission’s broader efforts to streamline reporting requirements and alleviate administrative burdens on businesses operating in the EU.
NEXT STEPS
To implement DAC9, Member States must transpose the directive into their national legislation by 31 December 2025. MNEs will be required to submit their first top-up tax information return by 30 June 2026, in accordance with the Pillar 2 Directive. Subsequently, tax authorities will need to exchange this information by 31 December 2026 at the latest.
