The European Commission has given Belgium, Bulgaria and Cyprus two months to complete the national transposition of Directive (EU) 2025/872, which sets rules for filing and exchanging GloBE top-up tax information returns under the Pillar Two regime, or risk referral to the Court of Justice of the EU.
The European Commission issued reasoned opinions to Belgium, Bulgaria, and Cyprus for failing to fully transpose Directive (EU) 2025/872 (DAC9), which establishes rules for the filing and exchange of GloBE Information Returns (top-up tax information returns) as part of its infringement package published on 7 July 2026.
Commission calls on Belgium, Bulgaria and Cyprus to finalise the implementation of the information exchange rules on administrative cooperation in the field of taxation
The European Commission has decided to send reasoned opinions to Belgium (INFR(2026)0015), Bulgaria (INFR(2026)0021) and Cyprus (INFR(2024)0030) for failing to fully transpose Directive (EU) 2025/872, which amends the Directive on administrative cooperation in the field of taxation (Directive 2011/16/EU).
The Directive requires Member States to standardise the collection of the top-up tax information return and to automatically exchange the information in that return. The top-up tax information return is part of the filing obligations laid down in Directive (EU) 2022/2523 (Pillar Two Directive) on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the Union.
Belgium, Bulgaria and Cyprus have so far not adopted or notified all national transposition measures, while tax authorities across the EU should be able to start exchanging information on multinational companies within the scope of the Pillar Two Directive as from June 2026.
In January 2026, the Commission sent letters of formal notice to the Member States for failing to fully implement the rules of the Directive. Therefore, the Commission has decided to issue reasoned opinions to Belgium, Bulgaria and Cyprus, which now have two months to respond and take the necessary measures. Otherwise, the Commission may decide to refer the cases to the Court of Justice of the European Union with requests for financial sanctions.
