EU: EU approves tax cooperation rules

Minimum corporate taxation: moving forward with cooperation and exchange of information between member states. The EU Council tightens the screws on taxation and business by approving the directive on tax cooperation — better known as DAC9 — aiming to put in force the G20/OECD global agreement on international tax reform provisions reached on July 2, 2021.

The proposed directive on minimum taxation of large corporations — which will impose a tax of at least 15 percent on every company with an annual turnover of over 750 million euros — ties in with the issue of digital taxation, i.e., the scheme to make sure that web operators, starting with the US giants, pay their share of taxes. While minimum taxation (Pillar 2) is EU, tax policy for internet operators (Pillar 1) is part of an agreement with the OECD and thus subject to international agreement. The agreement reached today (April 14) in the EU Council refers to Pillar 2.

The understanding reached among the ministers of the 27 member states expands tax transparency regulations. Specifically, it simplifies reporting for large companies by allowing the central filing of top-up tax information return (TTIR), i.e., one company file for the entire group concerned, instead of filing locally, i.e., separately for corporate entities. It also introduces a standard form for filing the TTIR throughout the EU, in line with that developed by the G20/OECD Inclusive Framework on Base Erosion and Profit Shifting (BEPS).

The new DAC9 Directive will enter into force the day after its publication in the Official Journal of the European Union. By December 31, 2025, Member states must adopt and publish the laws, regulations, and administrative provisions necessary to comply with this directive. The first integrated tax reporting is scheduled for June 30, 2026.