DAC9: automatic exchange of Pillar Two information in the EU

The ninth DAC amendment

On 6 May 2025 the OJEU published Directive (EU) 2025/872 (DAC9), the ninth amendment to the Directive on administrative cooperation. Its goal: standardise the exchange of the GloBE Information Return (GIR) between Member States and eliminate multiple-filing obligations.

How it works

• The group files a single GIR, in the UPE jurisdiction or a designated entity, .
• The receiving administration automatically distributes the relevant information to other jurisdictions under OECD format.
• Transposition deadline: 31 December 2025.

Critical timelines

Implications for LatAm groups with UPE in LatAm

If the ultimate parent is outside the EU but the group has European presence subject to Pillar Two:

• Designate a European filing entity (typically the Luxembourg, Dutch or Spanish holding).
• Centralise GloBE consolidation in a single finance team.
• Ensure the group ERP can generate the 250+ GIR fields.

Recommendation

Colombian and Mexican groups with European sub-holdings should start GIR dry-runs during H2 2025, identifying information gaps before the first real submission.