On April 14, 2025 the Council of the European Union (Hereinafter: the Council) adopted the DAC9 Directive. The adopted Directive further amendments Directive 2011/16/EU on administrative cooperation in the field of taxation. The objective of the DAC9 directive is to put into operation specific provisions of the Pillar 2 Directive (Council Directive (EU) 2022/2523 of December 15, 2022) that implemented in the EU the G20/OECD global agreement on international tax reform.

DAC9 complements the Pillar 2 Directive (Directive (EU) 2022/2523) by streamlining filing obligations for multinational enterprise groups (MNEs) that are within its scope. DAC9 introduces a centralised framework for the exchange of the information contained in those filings. In doing so, DAC9 brings about significant simplification for business, as it enables MNEs to file only one Top-up Tax Information Return (TTIR), at central level, for the entire group, as opposed to multiple filing being made by each constituent entity of the MNE group, at local level. 

The DAC9 Directive also introduces a standard form for filing the TTIR across the EU, in line with the one developed by the G20/OECD's Inclusive Framework on Base Erosion and Profit Shifting (BEPS).

Furthermore the DAC9 Directive also extends the framework for automatic exchange between member states to cover TTIR.

The DAC9 directive will enter into force the day after its publication in the Official Journal of the European Union. Member states will have to adopt and publish, by 31 December 2025, the laws, regulations and administrative provisions necessary to comply with this directive. The first top-up tax reporting is due by 30 June 2026. Countries opting to delay the implementation of the Pillar 2 Directive are still required to transpose DAC 9 by the same deadline.

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