DAC9 introduces new rules for sharing top-up tax information and filing obligations under the Pillar Two GMT Directive (Directive (EU) 2022/2523).

Luxembourg’s government submitted a draft bill to the parliament to implement Council Directive (EU) 2025/872 of 14 April 2025 (DAC9) on 24 July 2025.

DAC9 introduced new rules for sharing top-up tax information and implementing filing obligations under Directive (EU) 2022/2523 (Pillar Two Global Minimum Tax Directive).

The new rules allow ultimate parent entities or designated filing entities of an MNE group to file the top-up tax information return under Directive (EU) 2022/2523. This removes the need for other constituent entities in different EU Member States to file separately. DAC9 also provides filing rules and a standard template for the return.

Member States must adopt the necessary laws and regulations to comply with DAC9 by 31 December 2025.

Additionally, a new draft Grand-Ducal regulation on Article 50 of the Pillar Two Law has been issued, introducing the standard form for the GloBE Information Return (GIR) to be used by Luxembourg constituent entities, in accordance with the Annex to DAC9.