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European Council adopts DAC9 expanding tax transparency rules

14 May 2025
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On 14 April 2025, the European Council adopted another amendment to the Directive on administrative cooperation in the field of taxation (DAC9), extending exchange of information and cooperation into the Pillar 2 area.

The purpose of DAC9 is to streamline the filling obligations of multinational enterprise groups in the scope of Directive (EU) 2022/2523 (MNEs and the Pillar 2 Directive).

DAC9 enhances tax cooperation among EU member states and aligns with global standards on tax fairness.

Key changes

Key amendments under DAC9 include:

  • Simplified reporting: MNEs can submit reporting through a group-level top up tax information return (TTIR) - one company will file reporting for its entire group.
  • Introduction of a standard form: Introduction of a standard form for the purposes of filing the TTIR across the EU.
  • Automatic exchange: DAC9 broadens the automatic exchange of information system among EU member states to cover TTIR.
Timelines and implementation

DAC9 entered into force on 7 May 2025 and Member states must transpose the directive within their domestic law by 31 December 2025.

The first reporting deadline for TTIRs is set for 30 June 2026, ensuring sufficient time for preparation.

Countries that delay the implementation of the Pillar 2 Directive must still comply with the requirements of DAC9 under the same deadline.

For more information, the publication of the EU Council can be found here.