As Cyprus assumes the Presidency of the EU Council for the first half of 2026, there are significant tax and compliance priorities that multinational enterprises (MNEs) need to be aware of. Among the major updates are the advancements in the implementation of DAC8 and DAC9, two key directives concerning administrative cooperation and transparency in the EU. The first half of 2026 promises critical progress in simplification, anti-abuse measures, and global tax cooperation.
In this article, we’ll take a closer look at the priorities of the Cyprus EU Council Presidency, the state of play on DAC8 and DAC9, and how these developments impact Transfer Pricing compliance for businesses in the EU.
Cyprus EU Council Presidency Priorities for 2026: A Snapshot
Cyprus has unveiled its EU Presidency program for the first half of 2026, with several priorities that will affect businesses, tax professionals, and multinational corporations operating within the EU.
1. Simplification of Tax Rules
One of the major initiatives under Cyprus’ presidency is to begin work on simplifying the administrative cooperation directives (DAC), which will focus on recasting the existing frameworks. The aim is to streamline direct taxation rules for a more efficient tax system across EU member states.
What this means for businesses:
- A potential reduction in bureaucratic burden as EU tax rules become more transparent and straightforward
- Easier compliance with administrative reporting requirements, especially for multinational groups
2. Anti-Abuse Measures
The EU will continue to focus on combatting tax abuse by updating its list of non-cooperative jurisdictions. The goal is to ensure that tax avoidance practices are curbed and that EU member states work cohesively against aggressive tax planning.
What this means for businesses:
- An increased focus on ensuring global tax compliance
- Enhanced scrutiny of intercompany transactions, especially where tax havens are involved
3. Progress on Own Resources in the New Multiannual Financial Framework (MFF)
Cyprus will also focus on advancing the EU’s own resources proposals, specifically for the multiannual financial framework (MFF) for 2028-2034, which includes setting the EU budget and funding mechanisms.
What this means for businesses:
A possible shift in how taxation resources are allocated and how businesses contribute to the EU’s financial framework
4. International Tax Cooperation via the United Nations Framework
Cyprus will advance the EU’s efforts to engage in international tax cooperation through the United Nations Framework Convention.
What this means for businesses:
- Greater alignment of global tax standards, especially on Pillar Two and other OECD-based tax reforms
5. Savings and Investments Union (SIU)
The advancement of the Savings and Investments Union is on Cyprus’ agenda, which may impact how businesses manage cross-border investments and savings across the EU.
What this means for businesses:
Potential changes in tax treatment and regulatory oversight of cross-border investment activities
DAC8 and DAC9: State of Play for 2026 and Beyond
Alongside the broader EU tax reforms, the implementation of DAC8 and DAC9 remains a key issue for multinational companies operating in the EU.
DAC9: The Exchange of Pillar Two Information
DAC9 establishes a framework for the exchange of Pillar Two information among EU member states. This directive requires member states to transpose the regulations by December 31, 2025, which will impact Pillar Two compliance across the EU.
What businesses need to do: Ensure that their Pillar Two compliance mechanisms are in place, including tracking effective tax rates (ETR) across different jurisdictions.
Impact on Transfer Pricing:
Pillar Two disclosures will affect Transfer Pricing models, particularly in terms of tax rate alignment and the allocation of profits across jurisdictions.
DAC8: The Exchange of Information on Cryptoassets
DAC8 introduces provisions for the exchange of information on cryptoassets, effective from December 31, 2025. This is part of the EU’s effort to increase transparency in emerging sectors such as cryptocurrency.
What businesses need to do: Stay updated on cryptoasset regulations and how they affect Transfer Pricing and tax reporting for crypto-based transactions.
Impact on Transfer Pricing:
The regulations will bring greater clarity on how cryptoassets are handled for tax purposes, and businesses may need to update their Transfer Pricing policies to reflect these changes.
EU Public Country-by-Country (CbC) Reporting: What You Need to Know
With public CbC reporting rules now in effect across EU member states, multinational enterprises (MNEs) will be required to disclose information on their global tax position in a public format.
The first round of CbC disclosures will be due at the end of 2026, for the financial year 2025.
What businesses need to do:
Ensure full compliance with public CbC reporting requirements, including clear documentation of global profits, tax rates, and intercompany transactions.
Impact on Transfer Pricing:
Transfer Pricing documentation will need to be aligned with CbC reporting disclosures, ensuring that all related-party transactions are transparent and compliant with OECD guidelines.
How TransferPricing.report Supports EU Compliance
At TransferPricing.report, we help businesses navigate the complex landscape of EU tax reforms, including Pillar Two compliance, DAC8, DAC9, and CbC reporting. Our services include:
- Pillar Two compliance support for EU member states
- DAC8 and DAC9 readiness and implementation guidance
- Audit-ready Transfer Pricing documentation for EU tax transparency
- Global tax compliance strategies for multinational groups
Final Takeaway: Preparing for the Cyprus EU Council Presidency and Upcoming Tax Changes
Cyprus’ presidency will bring significant developments to EU tax policy, with DAC8, DAC9, and other measures likely to reshape how businesses handle Transfer Pricing and tax transparency. Preparing early for these changes will help ensure compliance and reduce audit risk.
- Operating in the EU?
- Unsure how DAC8,
DAC9, and Pillar Two will affect your Transfer Pricing policies?
Contact our Transfer Pricing experts today and stay ahead of the upcoming EU tax reforms.
This is general information only and not professional advice. Consult a professional before acting.