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

Official Journal of the European Union EN L series 2025/872 6.5.2025 COUNCIL DIRECTIVE (EU) 2025/872 of 14 April 2025 amending Directive 2011/16/EU on administrative cooperation in the field of taxation THE COUNCIL OF THE EUROPEAN UNION, Having regard to the Treaty on the Functioning of the European Union, and in particular Articles 113 and 115 thereof, Having regard to the proposal from the European Commission, After transmission of the draft legislative act to the national parliaments, Having regard to the opinion of the European Parliament (1), Having regard to the opinion of the European Economic and Social Committee (2), Acting in accordance with a special legislative procedure, Whereas: (1) Council Directive (EU) 2022/2523 (3) implements the agreement reached on 8 October 2021 by the OECD/G20 Inclusive Framework (‘OECD/G20 IF’) on base erosion and profit shifting (‘BEPS’) and closely follows the Global Anti-Base Erosion Model Rules (Pillar Two) of Organisation for Economic Co-operation and Development (OECD) (‘OECD Model Rules’) agreed by the OECD/G20 IF on 14 December 2021. Directive (EU) 2022/2523 introduces a qualified income inclusion rule (‘IIR’) and a qualified undertaxed profit rule (‘UTPR’). That Directive also allows Member States to introduce their own qualified domestic top-up tax (‘QDTT’). (2) Directive (EU) 2022/2523 already establishes the rules for filing Top-up tax information returns and outlines broadly the information categories...