Pillar Two: EU Council Adopts DAC9 Proposal

On 14 April 2025, the EU Council adopted the proposed amendment to the Directive on Administrative Cooperation to facilitate the filing and exchanging of Pillar Two-related information in the EU (known as DAC9). DAC9 will enter into force the day after its publication in the Official Journal of the EU. DAC9 will have to be implemented into national law of EU Member States by 31 December 2025, i.e., six months prior to the first filing deadline of the Top-up Tax Information Returns (TTIR) for most groups in scope of Pillar Two rules.

Background

The implementation of the OECD's Pillar Two global minimum taxation model rules (GloBE Rules) has been to a large extent harmonised in the EU through Council Directive (EU) 2022/2523 of 14 December 2022 (Pillar Two Directive). Article 44 of the Pillar Two Directive sets out the filing requirements that constituent entities of in-scope groups must comply with. By default, each constituent entity must file a TTIR in the EU