First announced: Council adopted DAC9 on April 14, 2025 (Directive amending Directive 2011/16/EU).
Submitted by: NYBACS Compliance Desk
On 14 April 2025 the EU Council adopted DAC9 to expand tax information exchange and operationalise parts of the Pillar Two regime.
DAC9 strengthens cross-border cooperation to administer minimum effective taxation.
MNEs should centralise records and expect more coordinated tax authority enquiries.
What changed: DAC9 (an amendment to the EU Directive on administrative cooperation in taxation) was adopted by the Council on 14 April 2025 to enable broader information exchange between Member States for Pillar Two top-up tax enforcement and other minimum effective taxation measures. The directive clarifies reporting and cooperation protocols that will support the implementation of the EU Pillar Two regime.
Who’s affected: Multinational groups operating in EU Member States and any third-party service providers holding tax-relevant information (payment processors, payroll service providers, digital platforms).
Immediate actions (NYBACS checklist):
- Centralise tax data and documentation for Pillar Two calculations and related country-by-country records.
- Implement workflows to respond to multi-jurisdictional enquiries and information-requests.
- Confirm transfer-agents, banks and payroll providers can produce timely data needed for cross-border exchanges.
Practical notes: DAC9 increases the probability of coordinated cross-border tax queries — organisations should ensure internal tax governance, record retention and point-of-contact protocols are robust.
