ARTICLE
17 March 2025

EU Proposal To Simplify Pillar 2 Filing Obligations For MNEs Adopted

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Arendt & Medernach

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Arendt combines the entire value chain of services dedicated to Asset Managers, Banks, Insurers, Public Institutions and Private Clients operating in Luxembourg.

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Legal & Tax

We assist clients in structuring and running their business from a legal and tax standpoint across Luxembourg. Our teams directly serve international clients or work in close collaboration with foreign partner law firms.

Together with our regulatory consultants and investor services experts, we bridge the gap between legal/tax advice and its implementation. We deliver best-in-class services along our clients’ business life cycles.

The 450 legal experts of Arendt & Medernach have a wealth of experience in a wide variety of specialisations. Together, they are able to advise on a complete range of 15 complementary practice areas

On 11 March 2025, the Council of the EU reached a political agreement on a proposal, known as DAC 9, to amend the directive on administrative cooperation in tax matters.
European Union Tax

On 11 March 2025, the Council of the EU reached a political agreement on a proposal, known as DAC 9, to amend the directive on administrative cooperation in tax matters. DAC 9 is closely linked to the Pillar 2 Directive, which aims to ensure a global minimum level of taxation for multinational enterprise groups (MNEs) and large-scale domestic groups in the EU.

DAC 9 incorporates the OECD's GloBE top-up tax information return into EU law and simplifies the filing obligations of MNEs. It allows MNEs to move away from local reporting to a centralised report filed by the ultimate parent entity of the MNE or by a designated entity, instead of each constituent entity of the group filing a separate report. DAC 9 also establishes a framework to facilitate the communication of top-up tax information returns to the other Member States in line with the OECD framework.

Member States will have until 31 December 2025 to implement DAC 9 into domestic law.

MNEs are expected to file their first top-up tax information return by 30 June 2026, as required under the Pillar 2 Directive. The relevant tax authorities must communicate this information to other Member States by 31 December 2026 at the latest.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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