Back to research

Compliance

Pillar 2 and DAC Reporting: Building a Reliable EU Information-Exchange Workflow

Recent Commission enforcement activity highlights the continuing importance of standardized Pillar 2 top-up-tax information returns and automatic exchange between EU tax authorities. Multinational groups should treat data ownership, filing calendars, and jurisdictional implementation tracking as core compliance controls.

By Nomadic Tax Institute research team · 5-8 min read · Published

Why DAC and Pillar 2 remain operational priorities

The EU Directive on Administrative Cooperation, commonly called DAC, provides the legal framework for tax-information exchange between Member States. It is particularly relevant to multinational groups because the Pillar 2 rules require information concerning the top-up tax information return to be collected and exchanged in a standardized way.

In October 2026, the European Commission stated that Czechia had not fully transposed the EU rules implementing standardized collection and automatic exchange of Pillar 2 top-up-tax information. The Commission noted that tax authorities across the EU should be able to begin exchanging relevant information from June 2026. The enforcement action is a reminder that domestic implementation can differ in timing even where the underlying EU obligation is common.

What a group should control

A group’s compliance process should identify four separate responsibilities:

  1. Determine scope. Confirm whether the group falls within the Pillar 2 rules based on consolidated revenue and group structure.
  2. Prepare the data. Establish ownership for jurisdictional effective tax rates, covered taxes, substance-based exclusions, deferred-tax information, and domestic minimum-tax adjustments.
  3. Coordinate filings. Track whether the designated filing entity can file centrally and whether local notifications are still required in each relevant Member State.
  4. Validate exchange readiness. Confirm that the tax authority in each jurisdiction has adopted the necessary forms, electronic formats, and filing channels.

Practical example

A multinational group headquartered outside the EU may have subsidiaries in Germany, France, and Czechia. Even if the group prepares one global data package, it should maintain a country matrix showing each entity’s local notification requirements, filing authority, approved format, deadline, and responsible signatory. A central filing arrangement should not be assumed to eliminate every local procedural step.

Actionable controls

  • Maintain a DAC/Pillar 2 obligations register by entity and jurisdiction.
  • Reconcile the Pillar 2 information return to the group’s tax provision and statutory accounts.
  • Keep evidence for jurisdictional elections and safe-harbour positions.
  • Test electronic filing credentials and authorized-representative access before the filing window.
  • Review Commission enforcement notices for countries with delayed or incomplete transposition.
  • Escalate inconsistencies between local legislation and the group’s global reporting model.

The key lesson is that Pillar 2 compliance is not only a tax-calculation exercise. It is also an information-governance and filing-technology project. Groups that centralize calculations but neglect local notification and exchange mechanics may still face avoidable compliance risk.

Sources

1taxation-customs.ec.europa.eu
Official source for Pillar 2 and DAC Reporting: Building a Reliable EU Information-Exchange Workflow
2malta.representation.ec.europa.eu
Official source for Pillar 2 and DAC Reporting: Building a Reliable EU Information-Exchange Workflow
3taxation-customs.ec.europa.eu
Official source for Pillar 2 and DAC Reporting: Building a Reliable EU Information-Exchange Workflow