Skip to main content
European Commission logo
enen
Business, Economy, Euro
Taxation and Customs Union

DAC1

The main goal of DAC1 AEOI is to ensure tax fairness between the taxation of income received and wealth held nationally by EU taxpayers and income received and wealth held in other Member States.

DAC1

Directive 2011/16/EU provides for automatic exchange of six categories of income and assets: employment income, pension income, director fees, income and ownership of immovable property, life insurance products and royalties (‘DAC1 AEOI’). Non-custodial dividends are added to these categories as from 2026. 

The main goal of DAC1 AEOI is  to ensure tax fairness between the taxation of income received and wealth held nationally by EU taxpayers and income received and wealth held in other Member States. Member States can also use the information received to check if taxes have been levied in the other Member States to avoid double taxation of the taxpayer. 

Background 

Member State tax authorities need relevant information from other tax authorities in the EU to ensure fair taxation and avoid double taxation. Tax authorities have access to information at national level to ensure compliance. For example, employers and taxpayers are obliged to report information that can be used by tax authorities to pre-fill information in annual tax returns, include DAC1 AEOI information in taxpayer web-portals, and be used for compliance actions like risk assessment and audit. Further, most Member States have withholding tax systems like levying tax at source, for example, on employment and capital income paid out at national level. 

These compliance actions mentioned above are not normally available to tax authorities in the case of income received from and assets held in other Member States. DAC1 AEOI information can provide tax authorities with the possibility to perform compliance activities for foreign income/assets that are equivalent to those existing for national income/assets. For taxpayers, this can help to ensure tax fairness in that all income/assets, irrespective of the source or location, will be subject to the compliance actions of the tax authorities.

In 2022/23 Member States reported exchanging information between them of EUR 24 billion related to 13.6 million taxpayers for the following DAC1 categories:

 01.07.2022-30.06.2023
 No. Taxpayers (millions)Income (EUR billions)No. MS reporting
DAC1 Employment Income2.442.725
DAC1 Pension Income3.615.215
DAC1 Immovable Property Income4.52.319
DAC1 Immovable Property  Ownership3.117615
Total13.6236.2 

Member States reported obtaining EUR 117 million in additional tax revenues as a result of DAC1 Employment Income and Pension Income, mainly as a result of risk assessment actions, for the tax year 2022 (on the basis of data provided by 13 Member States).

Scope

The information to be collected by tax authorities are for the following asset and income categories:

  1. income from employment;
  2. director’s fees;
  3. life insurance products not covered by other Union legal instruments on exchange of information and other similar measures;
  4. pensions;
  5. ownership of and income from property;
  6. royalties;
  7. non-custodial dividend income other than income from dividends exempt from corporate income tax pursuant to Articles 4, 5 or 6 of Council Directive 2011/96/EU (the Parent-Subsidiary Directive)

Information on (6) royalties will be reported for the first time in 2025 in relation to tax year 2024. The inclusion of DAC1 AEOI of royalties was provided through an amendment to the DAC (DAC7). 

Information on (7) non-custodial dividends will be reported for the first time in 2026 in relation to the tax year 2025. The inclusion of DAC1 AEOI for non-custodial dividends was provided through an amendment to the DAC (DAC8).

Income categoryTax years concernedFirst year of AEOI
Employment income 2014 and subsequent years2015
Director’s fees2014 and subsequent years2015
Pension income2014 and subsequent years2015
Life insurance information2014 and subsequent years2015
Immovable Property income and ownership2014 and subsequent years2015
Royalties2024 and subsequent years2025
Non-custodial dividends2025 and subsequent years2026

The information to be collected for DAC1 AEOI depends on national legislation in the sending Member State, including definitions related to these income and asset categories. For example, in the case of pensions this could include private pensions and public sector pensions. 

The information to be collected also depends on the availability of such information in the Member State itself. For example, in the case of (e) ownership of and income from property, Member States have established national real estate and property registers which means that such information can be collected and reported to other Member States. Further, some competent authorities for taxation have information that is reported or available to them nationally, for example for rental income and transactions of buying and selling real estate, which can then be reported to other Member States. Member States have committed to exchange with each other 5 out of 6 categories in 2025, and 6 out of 7 categories in 2026.

Depending on the DAC1 AEOI category, and according to the data available to Member States, information is exchanged on all types of residents, both natural persons and legal entities. For example, for DAC1 IP, information is collected on and reported on both natural persons directly owning real estate or a company that owns real estate. 

Reporting of the DAC1 income and asset categories

The DAC1 AEOI information collected by the tax authority of each Member State is then reported on annual basis by the Member State to the tax authority of the Member State of residence of the taxpayer. This is done within six months after the end of the relevant tax year. For example, for the tax year 2024, information should be reported by a Member State to other Member States by 30 June 2025.

The diagram below illustrates the reporting exchange flow between Member States.

Legal texts