Council of the European Union 14 April 2025, Council Directive (EU) 2025/872 of 14 April 2025 amending Directive 2011/16/EU on administrative cooperation in the field of taxation

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Council Directive (EU) 2025/872 amends Directive 2011/16/EU to establish a framework for the mandatory automatic exchange of information regarding Top-up tax information returns, facilitating the operational implementation of the global minimum level of taxation for multinational enterprise groups. The Directive introduces standardized reporting templates and dissemination protocols for the exchange of jurisdictional tax data between Member States to ensure the correct application of qualified income inclusion and undertaxed profit rules. Member States are required to transpose these measures by 31 December 2025, with general application commencing from 1 January 2026.AI