Council of the European Union Reaches Political Agreement on DAC9
The Council of the European Union has agreed on DAC9, enhancing tax transparency and compliance for multinational enterprises and large domestic groups.
On 11 March 2025, the Economic and Financial Affairs Council (ECOFIN) reached a political agreement on a proposal for a Directive amending the Directive on Administrative Cooperation (2011/16) (DAC), also referred to as DAC9.
The DAC9 proposal establishes a standardized form (top-up tax information return) in line with the GloBE Information Return developed by the G20/OECD's Inclusive Framework on Base Erosion and Profit Shifting (BEPS), which multinationals and large domestic groups will have to use to comply with the filing obligations established under the Minimum Taxation Directive (2022/2523) and transposed into the domestic laws of the Member States.
The agreed proposal also provides for the automatic exchange of the information included in the top-up tax information return, as approved, and enables MNEs to switch from local to central filing of the top-up tax information return.
The version of the proposal that was agreed upon will be subject to legal linguistic work, and the final version will still have to be formally adopted by the Council.
All Member States will have to implement DAC9 by 31 December 2025, even those which have exercised the option to delay the implementation of the Minimum Taxation Directive (2022/2523).