Global Daily Tax News, Belgian, Bulgarian, Cypriot Pillar Two Regimes Found Lacking, (Jul 9, 2026)

Belgium, Bulgaria, and Cyprus have failed to properly implement provisions from the ninth Directive on Administrative Cooperation in tax matters (DAC9) concerning Pillar Two.

DAC9 is intended to simplify reporting for large corporations under the EU Minimum Tax Directive by enabling central filing of a top-up tax information return (TTIR), eliminating the need for local filing. It introduces a standard form for filing the top-up tax information return (TTIR) across the EU, in line with the one developed by the G20/OECD's Inclusive Framework on Base Erosion and Profit Shifting.

DAC9 also provides for the exchange of these returns among relevant member state tax authorities.

Member states were required to adopt and publish laws, regulations, and administrative provisions necessary for the implementation of the Directive by December 31, 2025.

The European Commission has decided to escalate infringement proceedings against the three member states for failing to fully transpose the Directive into domestic law.

The Commission said: "Belgium, Bulgaria, and Cyprus have so far not adopted or notified all national transposition measures, while tax authorities across the EU should be able to start exchange information on multinational companies in scope of the Pillar 2 Directive as from June 2026."

In January 2026, the Commission sent letters of formal notice to the member states for failing to fully implement the rules of the Directive. Therefore, the Commission has decided to issue reasoned opinions to Belgium, Bulgaria, and Cyprus, which now have two months to respond and take the necessary measures. Otherwise, the Commission may decide to refer the cases to the Court of Justice of the European Union with requests for financial sanctions.