DAC 9 – Information Exchange for Global Minimum Taxation (Pillar 2 Implementation)

DAC 9 (Directive 2024/3024/EU) is the ninth amendment to the EU Administrative Cooperation Directive and establishes the legal framework for the automatic exchange of GloBE Information Returns (GIR) between EU member states. It complements the EU Minimum Taxation Directive (Pillar 2 Directive, 2022/2523/EU).

• Purpose: Multinational groups subject to minimum taxation (15% effective minimum tax rate) must file a GloBE Information Return. DAC 9 enables this return to be filed once in one member state and then automatically forwarded to all other affected member states.
• Simplification: Without DAC 9, groups would need to report separately in each member state where they operate.
• Scope: Covers corporate groups with consolidated annual revenue of at least EUR 750 million.

Global minimum taxation (Pillar 2) was agreed by the OECD/G20 in October 2021 as part of the Two-Pillar Solution. The EU transposed Pillar 2 through Directive 2022/2523/EU (Minimum Taxation Directive), which requires member states to ensure an effective minimum tax rate of 15% for large multinational groups.

To simplify the associated reporting obligations (GloBE Information Return) and avoid duplicate filings, the Commission presented the DAC 9 proposal in July 2023. Directive 2024/3024/EU was adopted on 24 October 2024. The transposition deadline is 31 December 2025, and the first GIR report is due for fiscal years beginning on or after 31 December 2023.

DAC 9 applies to all EU member states and covers multinational groups and large domestic groups with consolidated annual revenue of at least EUR 750 million that are subject to the EU Minimum Taxation Directive. The ultimate parent entity or a designated filing entity within the EU is required to report.

• Single filing of the GloBE Information Return (GIR) with the tax authority of the filing member state.
• Automatic forwarding of the GIR by the filing member state to all other affected member states within three months of the filing deadline.
• Content of the GIR: identification of group entities, effective tax rates per jurisdiction, calculation of top-up tax, applied safe harbour rules.
• Filing deadline: 15 months after the end of the fiscal year (18 months in the first year of application).

2 corrections:
- effective_date 2025-01-01 is incorrect — entry into force was 13 November 2024
- official_url points to non-existent CELEX number 32024L3024
1 note.