With this implementing regulation, the EU aims to provide technical solutions to facilitate the automatic exchange of information between Member States under DAC9.
The European Commission (EC) announced on 7 July 2025 that it has adopted a regulation to facilitate the automatic exchange of top-up tax information between EU member states under Directive 2011/16/EU (DAC 9).
The new Implementing Regulation establishes a common IT schema based on the one developed by the Organisation for Economic Co-operation and Development (OECD). This will ensure full interoperability between reporting under DAC9 and the OECD framework, thereby minimising the administrative burden on tax authorities and businesses alike.
This initiative aims to provide technical solutions to facilitate information sharing, supporting the implementation of the Pillar Two directive. The ultimate objective is to ensure that taxpayers comply with their obligations under the Pillar 2 Directive, while also minimising the administrative costs associated with tax compliance. The adoption of this Implementing Regulation confirms, once again, the strong commitment of all Member States to ensuring the seamless implementation of the Pillar 2 Directive.
The adoption of this Implementing Regulation is part of the EU’s broader efforts to strengthen administrative cooperation in taxation, as outlined in the Directive on Administrative Cooperation (DAC). It is also fully in line with the ongoing efforts to simplify and reduce administrative burden for all stakeholders involved. The DAC has undergone several updates since its introduction in 2011, with the latest revision, DAC9, focusing on the exchange of top-up tax information return for the purposes of implementing the Pillar 2 Directive.
