Contributor: Yvonne Diamond, Director, Financial Services Tax, BDO
On 11 March 2025, the Economic and Financial Affairs Council (ECOFIN) arrived at a political agreement on a proposal, amending the Directive on Administrative Cooperation (2011/16) (DAC), also referred to as DAC9.
The amendment aims to streamline the filing obligations and reduce the compliance burden for companies arising under the Pillar Two Directive by enabling multi-national enterprises (MNEs) to file one top-up tax information return for the entire group at a central level, rather than multiple local filings.
A standardised form, aligned with the Global Anti-Base Erosion (GloBE) Information Return developed by the Organisation for Economic Co-operation and Development (OECD) and G20 Inclusive Framework, will be introduced in accordance with DAC9. The introduction of this form aims to ensure uniformity and reduce administrative burdens.
DAC9 also establishes a framework for the automatic exchange of tax information between EU Member States, facilitating efficient tax administration and compliance. It is designed to further facilitate the implementation of the global minimum tax rate of 15% for MNEs and large-scale domestic groups as stipulated by the Pillar Two Directive.
In terms of projected timelines, Member States are required to implement the directive into national legislation by 31 December 2025. MNEs are expected to file their first top-up tax information return by 30 June 2026, as required under the Pillar Two Directive. The relevant tax authorities must exchange this information with each other by 31 December 2026.
MNEs can file their information return centrally through the ultimate parent entity or through the designated filing entity. The expectation is that the directive will be welcome by Irish taxpayers, as the centralised filing system for top-up tax information returns should simplify tax compliance for MNEs.
Content published in Finance Dublin Irish Tax Monitor.