32025L0872#rec_10Council Directive (EU) 2025/872

Recital (10)

Directive (EU) 2022/2523 allows Member States in which no more than twelve ultimate parent entities of groups within the scope of that Directive are located, to elect not to apply the IIR and UTPR for a limited period of time. In such cases, a Member State, if it is not a QDTT-only Member State, should only start applying the rules on exchange of Top-up tax information returns (i.e. receive and send the information) when the election period under Directive (EU) 2022/2523 ends.

Text as published in the Official Journal, reproduced verbatim (including any typographical quirks of the source). For the authentic version, see EUR-Lex.