EU: Council reaches political agreement on DAC9

The Council of the European Union today reached a political agreement on a further amendment of Directive 2011/16/EU on administrative cooperation in the field of taxation (DAC9), just five months after the European Commission (EC) presented its proposal and following the opinions of the European Parliament and the European Economic and Social Committee. Read TaxNewsFlash

According to the EC release,

• DAC9 complements the Pillar Two 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 Two Directive.

Next steps

Member states need to implement the directive into national legislation by December 31, 2025. MNEs are expected to file their first top-up tax information return by June 30, 2026, as required under the Pillar Two Directive. The relevant tax authorities must exchange this information with each other by December 31, 2026, at the latest.

For more information, read a March 2025 report prepared by KPMG’s EU Tax Centre