DAC9 – Directive (EU) 2025/872 – establishes an EU-wide framework for the exchange of Pillar Two (GloBE) information between tax administrations, and groups operating in or through Ireland are directly affected by the filing and reporting obligations it introduces. Ireland's transposition status remains subject to national legislative process, and the Revenue Commissioners are the competent authority designated to receive DAC8 and DAC9 reports in Ireland. Groups with an Irish constituent entity or an Irish-headquartered ultimate parent entity should assess their exposure now, given that the European Commission opened infringement procedures on 30 January 2026 against member states that had not completed transposition of DAC8 and DAC9.
The EU Framework: DAC8 and DAC9 in Brief
Two distinct but related EU directives govern the current wave of automatic information exchange. DAC8 – Directive (EU) 2023/2226 – aligns EU reporting obligations for crypto-asset service providers with the OECD's Crypto-Asset Reporting Framework (CARF) and applies across all member states from 1 January 2026. DAC9 – Directive (EU) 2025/872 – addresses a different challenge: ensuring that the qualified domestic minimum top-up tax and global minimum tax information produced under the Pillar Two (GloBE) rules is shared automatically between the tax authorities of all member states in which a large multinational or domestic group has constituent entities.
Although DAC8 and DAC9 share a transposition timeline and were the subject of the Commission's January 2026 infringement action, their subject-matter differs substantially. Groups with no crypto-asset activity still face DAC9 obligations if they fall within Pillar Two scope; conversely, crypto-asset service providers subject to DAC8 may be outside the GloBE regime entirely. The two directives should be analysed in parallel rather than treated as a single compliance package.
Ireland-Specific Context: Revenue Commissioners and Transposition Status
Ireland enacted its domestic Pillar Two legislation – the qualified domestic top-up tax and the income inclusion rule – through Finance Act 2023 and subsequent regulations, positioning the Revenue Commissioners as the competent authority for GloBE-related compliance. The question that DAC9 now raises is how Ireland will integrate the GloBE Information Return (GIR) and the related exchange mechanism into Revenue's existing reporting infrastructure.
As of the date of this analysis, Ireland's formal transposition of DAC9 into domestic law is pending. The Commission's infringement procedures, opened on 30 January 2026, signal that the EU institutions are monitoring member state implementation closely. Where a directive is not yet transposed, groups cannot rely on domestic procedural rules to determine their exact filing deadlines, penalties or submission formats – these details remain subject to national implementing measures that have not yet been published in final form.
What is already clear is that the Revenue Commissioners will be at the centre of Ireland's DAC9 operation. Revenue has significant experience with FATCA, CRS and country-by-country reporting (CbCR), and DAC9 builds on that institutional infrastructure. However, the GIR is materially more complex than a CbCR filing, containing jurisdictional effective tax rate calculations, top-up tax computations and safe harbour elections. Groups should not assume that existing CbCR processes will translate without significant adaptation.
If your group has constituent entities in Ireland and you are mapping DAC9 filing obligations, our tax law team can assist with an early-stage impact assessment. Please reach out at info@ferrazwhitmore.com or visit our contacts page.
Who Is Affected: Scope of Pillar Two and DAC9 in an Irish Context
DAC9 applies to multinational enterprise (MNE) groups and large-scale domestic groups that fall within the Pillar Two scope – broadly, those with consolidated annual revenues meeting the relevant threshold in at least two of the four preceding fiscal years. Ireland's domestic Pillar Two legislation uses the same scoping rules, so the population of in-scope groups in Ireland is already defined by reference to the GloBE model rules.
The following categories of entity are particularly exposed to DAC9 obligations in an Irish context:
- Irish-headquartered MNE groups whose ultimate parent entity (UPE) is tax resident in Ireland and which therefore file the GIR with Revenue as the competent authority of the UPE jurisdiction.
- Irish constituent entities of non-EU MNE groups where the UPE jurisdiction has not enacted qualifying GloBE legislation equivalent to DAC9 – in such cases, Ireland may impose a secondary top-up tax or require a local GIR filing.
- EU-headquartered groups with an Irish subsidiary or branch where Revenue will receive exchanged GIR data from the UPE jurisdiction's authority under DAC9.
- Investment funds and regulated structures using Irish special purpose vehicles – these entities require careful analysis of the Pillar Two exclusions and the treatment of tax-transparent entities under the GloBE rules.
The Central Bank of Ireland's regulated population – insurance undertakings, fund managers and bank holding companies – also intersects with Pillar Two, and groups in those sectors should consider both the DAC9 information exchange dimension and any interaction with prudential reporting obligations.
The GloBE Information Return: Content, Filing and Exchange Mechanics
The GIR is the core document around which DAC9 operates. It is a standardised XML-based return developed by the OECD, containing detailed information about each constituent entity: jurisdictional effective tax rates, top-up tax amounts, safe harbour elections, ownership structure and more. Under DAC9, the competent authority of the UPE jurisdiction exchanges the GIR automatically with the competent authorities of all other jurisdictions where constituent entities are located.
For an Irish UPE filing with Revenue, this means that Revenue will transmit the relevant portions of the GIR to tax authorities in every jurisdiction where the group has a constituent entity. For an Irish constituent entity of a foreign-headed group, Revenue will receive data exchanged from the UPE jurisdiction's authority. In either scenario, the data held by Revenue about an Irish entity's effective tax position across the globe will be considerably more granular than anything available under CbCR alone.
Key procedural points that groups should monitor as Ireland's implementing legislation develops include:
- The deadline by which the GIR must be filed with Revenue in the UPE jurisdiction scenario – the OECD recommends filing within 15 months of the end of the fiscal year (18 months for the first year), but national implementing rules may modify this.
- Whether Ireland will permit surrogate parent entity (SPE) filings – where another group entity files the GIR on behalf of the UPE – and the conditions attaching to such elections.
- The format and submission channel accepted by Revenue's electronic systems.
- Penalty provisions for late, incomplete or incorrect GIR filings, which are expected to be introduced through the transposing legislation.
Cross-Border Dimensions: The Netherlands and Other Key Counterparties
Ireland's position as a hub jurisdiction for MNE group treasury, IP holding and regional headquarters structures means that DAC9 information exchange will flow heavily between Revenue and a relatively small number of counterpart tax authorities. The Netherlands is among the most significant, given the volume of Irish-Dutch group structures in the technology, pharmaceutical and financial services sectors. Our analysis of DAC9 Pillar Two filing obligations in the Netherlands explores the Dutch transposition approach and the practical implications for groups with a Dutch-Irish nexus.
Groups should also consider the position of third-country jurisdictions – the United States, the United Kingdom, Switzerland and Singapore feature prominently in Irish MNE structures – where Pillar Two legislation exists but DAC9 as an EU instrument does not apply. For constituent entities in those jurisdictions, the exchange of GIR data with Revenue will depend on bilateral competent authority agreements and the OECD's multilateral convention framework rather than DAC9 itself. This distinction matters for assessing what Revenue will actually receive about non-EU constituent entities and when.
The interaction with DAC8 is relevant where a group holds or transacts in crypto-assets. From 1 January 2026, DAC8 imposes reporting obligations on crypto-asset service providers in respect of EU-resident customers, and that data will also flow to Revenue. A group subject to both DAC8 and DAC9 should consider how Revenue may cross-reference the two data streams, particularly where crypto-asset gains affect the effective tax rate calculation under Pillar Two.
Data Protection and Information Governance Risks
The GIR contains highly sensitive commercial and financial data, including entity-level revenue and profit figures, tax computations and ownership details. Under DAC9, this data is transmitted between EU member state competent authorities in a largely automated manner. Groups operating in Ireland should be aware that the Data Protection Commission – Ireland's national supervisory authority under the GDPR – has oversight of how Revenue processes and stores personal data received through international exchange mechanisms.
In practice, the GIR is primarily about legal entities rather than natural persons, so the GDPR intersection is less acute than in DAC8 (where individual crypto-asset holders are directly identified). Nevertheless, groups with individual ultimate beneficial owners or complex trust structures may find that some GIR data touches on personal data in the GDPR sense. Legal advice on the data governance implications of DAC9 compliance is advisable before the first GIR is filed.
Strategic Recommendations for In-Scope Groups
Given the pace of regulatory development, groups with an Irish connection should take a number of preparatory steps ahead of the implementation of DAC9 in Irish domestic law:
- Confirm scope. Verify whether the group meets the Pillar Two revenue threshold and identify all Irish constituent entities, including intermediate holding companies, branches and tax-transparent entities registered with the Companies Registration Office (CRO).
- Map the filing responsibility. Determine whether the Irish entity is the UPE, a designated filing entity, or a recipient of exchanged data. Each position carries different obligations and different timelines.
- Assess safe harbour availability. The transitional CbCR safe harbour and the domestic minimum top-up tax safe harbour can significantly reduce GIR complexity for qualifying jurisdictions. Ireland's own low-tax profile in certain sectors means safe harbour eligibility requires careful analysis rather than assumption.
- Engage with Revenue early. Revenue has a track record of pre-filing engagement on complex international tax matters. DAC9 is sufficiently novel that early dialogue about format, timing and substance is likely to be productive.
- Review group structures in light of exchanged data. DAC9 will give Revenue a consolidated view of the group's global tax profile. Structures that were designed before this level of transparency existed should be reviewed to ensure they remain appropriate and defensible.
- Co-ordinate with legal and tax advisers across all relevant jurisdictions. The GIR is prepared at group level but has jurisdiction-by-jurisdiction consequences. Consistent positions across all constituent entity jurisdictions are essential to avoid contradictory data reaching multiple tax authorities simultaneously.
For groups in the technology, pharmaceutical or financial services sectors with significant Irish operations, the convergence of DAC8 (crypto-asset reporting from 1 January 2026), DAC9 (Pillar Two information exchange) and Ireland's domestic Pillar Two regime creates an information environment of unprecedented detail. Groups that have not yet mapped their full exposure risk being reactive rather than prepared when Revenue begins receiving and acting on exchanged GIR data.
Our Ireland tax law practice advises on DAC9 readiness, GIR preparation and cross-border Pillar Two compliance. To discuss your group's specific position, contact us at info@ferrazwhitmore.com.
Outlook: What to Watch in the Remainder of 2026
The most immediate development to monitor is Ireland's formal transposition of DAC9 into domestic legislation. Finance Bills and Revenue guidance notes are the primary vehicles through which the procedural details – filing format, deadlines, penalties – will be confirmed. The Commission's infringement action, initiated on 30 January 2026 against member states that had not transposed DAC8 and DAC9, adds urgency to the legislative timeline.
Separately, the OECD continues to publish administrative guidance on the GloBE rules, and further iterations of the GIR schema may affect what information groups are required to report and in what form. Groups should treat their DAC9 compliance framework as a living document rather than a one-time project.
Finally, the interaction between DAC9 and Ireland's corporate law framework deserves attention. Directors of Irish companies that are constituent entities of in-scope groups have fiduciary duties that include ensuring accurate and timely tax compliance. The corporate law dimension of Pillar Two – including board-level governance of GIR preparation and approval – is an area where legal and tax advisory functions should be working in close co-ordination.
If you would like to discuss DAC9 readiness, GIR governance or the Irish transposition timetable with our team, please write to info@ferrazwhitmore.com or use our contacts page to arrange a call.
Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Ferraz & Whitmore assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@ferrazwhitmore.com.