Riga: Latvian tax advisers are running final compliance dry-runs on Council Directive (EU) 2025/872, the so-called DAC9, with the first centralised top-up tax information returns now due by 30 June. The directive is the administrative spine of the Pillar Two minimum tax framework that the European Union transposed through the 2022 Minimum Tax Directive, and it is the first time the bloc has tied the international Inclusive Framework agreement to a standardised digital filing template. Riga’s finance ministry treats the file as a Baltic readiness test, given that several mid-cap multinationals headquartered in Latvia and Estonia sit just above the 750 million euro consolidated revenue threshold that triggers the regime.
The technical structure of DAC9 is deliberately conservative. It does not change the substantive top-up tax rules already inside the Minimum Tax Directive. What it does is replace twenty-seven national filing forms with a single GloBE Information Return template that flows through the standardised exchange architecture used for DAC2 and DAC6. The Commission tabled the proposal in October 2024 and the Council adopted the directive in April, leaving Member States with a transposition window that ended on 31 December 2025. The first returns covering financial year 2024 are due by 30 June 2026 under the standard 18-month deadline, with subsequent filings due 15 months after fiscal year end. Latvian tax administration officials have used the runway to test interoperability with the Commission’s central reporting hub before the June peak hits.
The political case for DAC9 has been less contested than the underlying Pillar Two architecture. Member State revenue authorities have a shared interest in a workable filing model because the alternative is twenty-seven parallel filings for the same group, each subject to local tax authority interpretation. The directive resolves that risk by carving out a single designated filing entity at parent or constituent level. Riga’s tax bar has flagged that the designation rules are workable but require constituent entities to lock down the chain of allocation before the 30 June filing date. Groups that delay the designation risk default to a constituent entity filing in every jurisdiction where the group operates, a fallback that almost no advisor recommends.
Implementation across Latvia’s mid-cap base has been smoother than across some larger jurisdictions. Latvia uses a corporate income tax model that taxes distributed profits rather than profits as they accrue, and the Minimum Tax Directive interacts with that base in a way that has required dedicated guidance. The State Revenue Service issued a circular in March clarifying the interaction between the qualified domestic top-up tax election and the distribution-based base, a piece of administrative work that several Riga firms had been pressing for since the Minimum Tax Directive entered into force. The circular eased anxiety about double-counting and brought a clear allocation rule for retained earnings inside the Pillar Two computation.
The bilateral dimension is also moving. The OECD Inclusive Framework’s central record system, which the Commission’s hub will mirror for intra-EU exchange, is still under technical stabilisation. Several non-EU jurisdictions that adopted the Pillar Two rules in parallel have signalled that their first GIR exchanges will follow the EU template. That signal matters for groups headquartered in Riga with operations in third countries that have adopted a qualifying minimum top-up tax, because it reduces the risk of duplicate reporting through divergent national templates.
The next test for the Latvian Treasury is enforcement. The directive sets minimum penalty levels but leaves the structure to Member States, and the Commission has indicated that the first enforcement review will land in late 2027 once the first full cycle has run. Riga officials want a unified penalty framework before that review, on the grounds that divergent penalty regimes risk recreating the very fragmentation that DAC9 was meant to compress. The June filing window will deliver the first hard read on whether the new architecture clears that test in practice.
