The new rules allow MNE groups to submit a single Top-up tax return, easing reporting requirements for entities across EU states.
Denmark’s Parliament passed Bill L 23 on 27 November 2025, introducing measures to implement Council Directive (EU) 2025/872 of 14 April 2025 (DAC9).
The updated rules allow the automatic exchange of Top-up tax information returns under Directive (EU) 2022/2523 (Pillar 2) and ultimate parent companies or their designated filing entities within an MNE group to submit a single, central Top-up tax information return under Directive (EU) 2022/2523, removing the requirement for other group entities in different EU Member States to file separate returns.
This central filing mechanism is designed to relieve other constituent entities in different EU Member States from submitting separate filings.
DAC9 also outlines filing rules and a standard template for the Top-up tax information return.
EU Member States are required to adopt and publish the necessary laws and regulations to comply with DAC9 by 31 December 2025.
Earlier, Denmark’s parliament reviewed draft Bill L 23 on 8 October 2025, which aimed to implement Council Directive (EU) 2025/872 (DAC9) adopted on 14 April 2025.
