DAC9 introduces new rules for sharing top-up tax information and filing obligations under the Pillar 2 GMT Directive (Directive (EU) 2022/2523).
The Slovak Republic published Law No. 291/2025 on 21 October 2025 in the Official Gazette on 10 November 2025, implementing Council Directive (EU) 2025/872 of 14 April 2025 (DAC9).
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.
The new rules streamline the exchange of Top-up tax information and establish the framework for implementing the filing obligations under Directive (EU) 2022/2523 (Pillar 2 GMT Directive). Under these rules, ultimate parent entities or designated filing entities of an MNE group can centrally file the Top-up tax information return, relieving other constituent entities across different EU Member States from the requirement to submit separate returns. EU Member States are required to adopt and publish the necessary laws and regulations to comply with DAC9 by 31 December 2025.
In addition to implementing DAC9, the law introduces amendments to apply OECD Pillar 2 guidance on deferred tax adjustments, transparent and reverse hybrid entities, and related matters.
The law takes effect on 31 December 2025.
Earlier, the Slovak Parliament approved a draft bill to implement Council Directive (EU) 2025/872 of 14 April 2025 (DAC9) on 22 October 2025.
