Agreement on Compromise Text DAC9

On March 11, 2025, the ECOFIN Council reached a political agreement on the DAC9 text, which establishes a framework for the exchange of information in the Pillar Two among EU member states. This compromise text introduces changes compared to the proposal from October 2024, including the latest Globe Information Return (GIR) template from the OECD dated January 2025.

The text stipulates that updates on supplementary tax information will be implemented through a new Council directive. The Council and the European Commission agreed on a declaration ensuring a swift adjustment of the directive in line with international developments.

After legal reviews, the Council can formally adopt the directive, which will come into effect upon publication in the Official Journal of the EU. Member states must transpose the directive into national law by December 31, 2025. It will be applied starting January 1, 2026, with the first exchange of information occurring within six months of the initial submission of supplementary tax information, no later than December 31, 2026.

For more detailed information, you can read the Euro Tax Flash prepared by our colleagues at the KPMG EU Tax Centre.