The EU Council has adopted DAC9 the 9th amendment to the Directive 2011/16/EU on Administrative Cooperation in the field of taxation (DAC). DAC9 supports the EU implementation of the OECD/G20 global minimum tax (Pillar 2).
The Purpose of DAC9
DAC9 establishes a harmonised reporting framework and strengthens automatic exchange of information between EU tax authorities in relation to Pillar 2. Under Pillar 2, certain large groups are required to pay a minimum effective tax rate of 15%.
Key Features
- Single Group-Level Filing – Eligible groups may submit a single Pillar 2 information return in one EU Member State, rather than filing multiple reports in each jurisdiction.
- Automatic Information Exchange – The filing Member State will share the information with other relevant EU tax authorities, ensuring consistent and coordinated enforcement of Pillar 2.
- Alignment with OECD Standards – The reporting format is aligned with the OECD Pillar 2 information return, promoting consistency between EU and international compliance requirements.
Who Is Affected
DAC9 applies to multinational and large domestic groups with consolidated annual turnover of at least EUR 750 million. Smaller businesses are not impacted.
Practical Impact
DAC9 is expected to reduce duplication of Pillar 2 filings and improve transparency and coordination among EU tax authorities. Groups within scope should ensure that Pillar 2 calculations and internal reporting processes are aligned with the new reporting and exchange framework.
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