Implementing Regulation to Facilitate Automatic Exchange of Tax Information under DAC9

The new Implementing Regulation lays down a common IT schema which is based on the one developed by the Organisation for Economic Co-operation and Development (OECD). This will ensure full interoperability between reporting under DAC9 and the OECD framework, thereby minimising the administrative burden on tax authorities and businesses alike.

Key objective

With this Implementing Regulation, the EU aims to provide technical solutions to facilitate automatic exchange of information between Member States under DAC9 which, in turn, supports the application of the Pillar 2 Directive. The ultimate objective is to ensure that taxpayers comply with their obligations under the Pillar 2 Directive, while also minimising the administrative costs associated with tax compliance. The adoption of this Implementing Regulation confirms, once again, the strong commitment of all Member States to ensuring the seamless implementation of the Pillar 2 Directive.

Background

The adoption of this Implementing Regulation is part of the EU's broader efforts to strengthen administrative cooperation in taxation, as outlined in the Directive on Administrative Cooperation (DAC). It is also fully in line with the ongoing efforts to simplify and reduce administrative burden for all stakeholders involved. The DAC has undergone several updates since its introduction in 2011, with the latest revision, DAC9, focusing on the exchange of top-up tax information return for the purposes of implementing the Pillar 2 Directive. 

Further information:

• Administrative cooperation in taxation
• Directive on administrative cooperation DAC
• Implementing regulation - EU - 2025/1325