When a Member State receives a Top-up tax information return from the ultimate parent entity or the designated filing entity of an MNE group under central filing in accordance with Directive (EU) 2022/2523, that Member State should communicate to other Implementing Member States or QDTT-only Member States, no later than 3 months after the filing deadline, or – in the case of receipt of a Top-up tax information return after the filing deadline – no later than 3 months after such receipt, the relevant specific parts of the Top-up tax information return in accordance with the dissemination approach approved by the OECD/G20 IF. As regards the first Reporting fiscal year, the deadline for communication of those relevant specific parts of the Top-up tax information return should be prolonged to 6 months after the filing deadline. Additionally, in order to accommodate any delays in the new system of exchange, in any case (i.e. for the first and next Reporting fiscal years) the first exchange will take place no earlier than 1 December 2026.
Text as published in the Official Journal, reproduced verbatim (including any typographical quirks of the source). For the authentic version, see EUR-Lex.
