The bill proposes amendments to Danish tax laws to align with EU rules on Top-up tax reporting under DAC9, due by 31 December 2025.
Denmark’s parliament is reviewing draft Bill L 23 on 8 October 2025, which aims to implement Council Directive (EU) 2025/872 (DAC9) adopted on 14 April 2025.
The draft law proposes amendments to the Minimum Taxation Act, the Tax Control Act, and the Act on Mutual Assistance in the Recovery of Taxes to align with DAC9. The directive facilitates the automatic exchange of Top-up tax information returns under Directive (EU) 2022/2523 (Pillar 2).
DAC9 introduces rules that allow the central filing of the Top-up tax information return by an ultimate parent entity or a designated filing entity within a multinational enterprise (MNE) group. 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, the Danish Ministry of Taxation opened a public consultation on draft legislation to implement Council Directive (EU) 2025/872 (DAC9) on 1 July 2025.
