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EU: Proposal for exchange of Pillar Two global minimum tax information between EU member states (DAC9)

DAC9 proposal would transpose the global anti-base erosion (GloBE) information return (GIR) into EU law.

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October 30, 2024

The European Commission (EC) on October 28, 2024, adopted a proposal for an extension of the Directive on Administrative Cooperation (DAC) to establish a framework for the exchange of Pillar Two global minimum tax information between EU member states (DAC9).

Specifically, the DAC9 proposal would transpose the global anti-base erosion (GloBE) information return (GIR) developed by the OECD into EU law by designating the GIR as the top-up tax information return envisaged in Article 44 of the EU Minimum Tax Directive and would implement a framework to facilitate the exchange of GIR information between EU member states. The proposal includes a dissemination approach for the exchange of GIR information so that member states only receive the information they need based on their role in the multinational enterprise group.

The EC has not yet opened a public consultation on the proposal. 

Read an October 2024 report prepared by KPMG’s EU Tax Centre

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