The landscape of international tax compliance is evolving fast, and Grant Thornton Malta is helping businesses stay ahead. With the EU's adoption of DAC9, the ninth amendment to the Directive on Administrative Cooperation, multinational and large domestic groups must now comply with a new EU-wide reporting regime for the Organisation for Economic Co-operation and Development’s (OECD) global minimum tax (Pillar Two).
DAC9 introduces the Top-up Tax Information Return (TTIR) – a single, group-level filing requirement designed to replace multiple local reports. It captures detailed, jurisdiction-level tax data, helping ensure consistency, transparency, and compliance across EU member states.
At the heart of this new directive lies Pillar Two, a global initiative developed by the OECD to ensure that large multinational groups pay a minimum level of tax, at least 15%, in every jurisdiction where they operate. This is achieved through the GloBE Rules, which calculate a jurisdictional effective tax rate and, where necessary, impose a top-up tax to reach the minimum threshold.
This framework applies to any group with consolidated annual revenues of €750 million or more and covers both EU-based and, in some cases, third-country entities linked to the EU. Even in cases where member states defer the application of Pillar Two rules, DAC9 requires the exchange of information if a Qualified Domestic Top-up Tax (QDTT) is imposed.
Malta has not yet implemented a QDTT, but the enabling provision introduced in the 2025 Budget Implementation Measures Act opens the door for its future adoption. This means that DAC9’s exchange obligations could become relevant in due course, and as such early preparation remains advisable.
Grant Thornton Malta advises businesses to begin reviewing their data systems now, assess whether they qualify for transitional simplified reporting, and identify a designated entity for TTIR filing. The firm is actively supporting clients to ensure readiness and avoid duplication across jurisdictions.
As tax transparency becomes central to international business, Grant Thornton Malta remains a trusted partner – helping clients understand the rules, meet deadlines, and turn regulatory change into a strategic advantage.
Contact our experts on [email protected] or visit https://www.grantthornton.com.mt/
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