On 14 April 2025, the Council of the European Union adopted a new amendment to Directive 2011/16/EU on administrative cooperation in taxation—commonly known as DAC9.
This latest revision is designed to ease the reporting requirements for multinational enterprise (MNE) groups under the EU’s Pillar 2 Directive (Directive (EU) 2022/2523). By introducing a centralized system for the exchange of top-up tax information, DAC9 significantly reduces the compliance burden for companies operating across multiple EU jurisdictions.
Rather than requiring each constituent entity of a multinational group to file its own report at the local level, DAC9 allows for a single, consolidated filing at the group level. This harmonized approach is expected to become the primary method for fulfilling reporting obligations under Pillar 2.
The amendment follows swiftly—less than six months after the European Commission’s proposal—and reflects the opinions of both the European Parliament and the European Economic and Social Committee. The rapid adoption of DAC9 demonstrates a strong collective commitment by EU Member States to implement Pillar 2 efficiently and with minimal administrative overhead.
What’s next?
EU countries must transpose the directive into national law by 31 December 2025. The first top-up tax information returns are expected from MNEs by 30 June 2026, with the exchange of this data between tax authorities to be completed by 31 December 2026.