DAC9 establishes rules for the exchange of top-up tax information and the related filing obligations under the Pillar Two Global Minimum Tax Directive.
The bill implementing the amendments to the domestic Pillar Two rules was published in the Official Gazette on 23 December 2025 (BGBl. I 353/2025) and entered into force on 24 December 2025.
The bill updates the Minimum Tax Act and aligns various national tax laws with European Union directives. Its primary objective is to refine the implementation of a global minimum tax framework for large corporate groups to ensure fair international competition.
The legislation details technical adjustments to deferred tax liabilities, reporting obligations, and cross-border administrative assistance between tax authorities. Additionally, it amends existing statutes, including the Income Tax Act and the Investment Tax Act, to align them with these new global standards.
This law also strengthens fiscal transparency and helps prevent tax base erosion within German jurisdiction.
DAC9 (Council Directive (EU) 2025/872) introduces new rules governing the exchange of top-up tax information and the implementation of filing obligations under Directive (EU) 2022/2523 (the Pillar Two Global Minimum Tax Directive).
