An administrative relief for multinationals: EU Adopts DAC9 Directive on Global Minimum Tax

On 24 April 2025, to streamline compliance with the global minimum tax (GloBE) rules, the European Union adopted the DAC9 Directive (Directive on Administrative Cooperation). While the directive offers multinational enterprise groups (operating within the EU) a simplified framework for meeting their administrative obligations, it also reinforces cross-border cooperation by mandating more efficient data exchange among EU tax authorities.

One of the cornerstone features of DAC9 is the centralized submission of the global minimum tax return: rather than requiring each group entity to file individually in their respective jurisdictions, the directive allows it for a designated group entity. Typically, the ultimate parent or a nominated subsidiary will be able to file a single Top-up Tax Information Return (TTIR) on behalf of the entire group.

In terms of deadlines and key dates, EU Member States must transpose the directive into national law by 31 December 2025, but it already applies to the 2024 financial year, with reporting obligations due by 30 June 2026. Following that, competent authorities must transmit the collected data by 31 December 2026, although from 2027 onward, this deadline will be shortened to three months after the submission date. Given the latter, businesses should strategically select the filing jurisdiction and entity, considering data availability and exceptions. Furthermore, it is also crucial for them to verify whether those jurisdictions have joined the OECD Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA); otherwise, local filing may still be required.

As tax authorities across the EU prepare to intensify their enforcement efforts, 2025 audit plans already prioritize a review of covered taxes such as corporate income tax and innovation contributions about GloBE compliance. Failing to adapt in time could result in increased scrutiny, administrative penalties or reputational risks. Going forward, tax authorities are expected to rely more heavily on automated cross-border data flows and to apply consistent standards when evaluating multinational groups’ compliance with the global minimum tax regime.