Global Daily Tax News, Romania Legislates For EU DAC9 On Pillar Two Information Exchange, (Feb 6, 2026)

Romania's Ministry of Finance has launched a public consultation on a draft Government Ordinance amending and supplementing the Fiscal Procedure Code to transpose into national legislation the provisions of the ninth EU Directive on Administrative Cooperation in tax matters (DAC9).

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 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 are required to adopt and publish, by December 31, 2025, the laws, regulations, and administrative provisions necessary to comply with DAC9, with the first top-up tax report due by June 30, 2026.

Taxpayers should use the form included in Annex VII to EU DAC9 to submit information on top-up tax liabilities under Section 53 of the Minimum Taxation Act, being identical, with minor linguistic adjustments, to the OECD's standard form, the GloBE Information Return (GIR). Romanian authorities have said the model of this form will be approved by Order of the president of the tax authority within 60 days from the entry into force of the legislation.