DAC9 introduces new rules for sharing top-up tax information and filing obligations under the Pillar Two GMT Directive (Directive (EU) 2022/2523).
The Slovak Republic’s Ministry of Finance has opened a public consultation on a draft bill to implement Council Directive (EU) 2025/872 of 14 April 2025 (DAC9) on 16 June 2025.
The draft legislation includes DAC9 implementation and amendments to adopt 2024-2025 guidance from the Inclusive Framework on deferred tax liability adjustments and rules for transparent and reverse hybrid entities.
DAC9 introduced new rules for sharing top-up tax information and implementing filing obligations under Directive (EU) 2022/2523 (Pillar 2 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.
The deadline for submitting comments on the draft bill is 3 July 2025.
