DAC9 Europe: The new tax cooperation directive and its consequences for non-residents in 2026

After DAC1, DAC2, DAC3, DAC4, DAC5, DAC6, DAC7, and DAC8 — here is DAC9. The ninth Directive on Administrative Cooperation in the field of taxation within the European Union. Each new directive tightens the grip of tax transparency in Europe: more information exchange, more automatic reporting, fewer grey areas. For French expatriates in Paraguay, DAC9 does not create any new taxes — but it radically changes the amount of information that the French tax authorities can obtain about your assets, income, and structures abroad.

This guide explains what DAC9 is, how it differs from previous directives, what information is now automatically exchanged, how it impacts non-residents and expatriates, and why the answer is not to flee transparency but to embrace it — from a country where transparency does not generate any tax.

DAC 1 to DAC 8: Summary of the European Transparency Arsenal

The Evolution over 15 Years

Before understanding DAC9, it is important to measure the progress made. The European Union has built a framework of tax transparency directive after directive:

Directive	Year	Purpose	Impact for Expatriates
DAC1	2011	General framework for administrative cooperation between EU member states. Exchange of information on request.	The French tax authorities can request information from any EU country about a specific taxpayer.
DAC2	2014	Automatic exchange of information on financial accounts (transposition of CRS into EU law).	European banks automatically report non-resident accounts to the tax authorities of their countries of residence. See our CRS guide.
DAC3	2015	Automatic exchange of tax rulings and advance pricing agreements between member states.	Secret tax deals between multinationals and European countries (like Luxembourg Leaks) are shared between administrations. Direct impact on individuals: low.
DAC4	2016	Automatic exchange of Country-by-Country Reporting (CbCR) for multinationals with turnover > €750M.	No direct impact on individuals. Targets multinationals.
DAC5	2016	Access for tax administrations to anti-money laundering information (beneficial ownership registers, KYC due diligence).	Tax authorities can access data collected for anti-money laundering. Your corporate structures (LLCs, SRLs, holdings) are visible.
DAC6	2018	Mandatory disclosure of cross-border tax arrangements (Mandatory Disclosure Rules). Intermediaries (lawyers, accountants, banks) must report aggressive tax planning schemes.	Significant impact. If your French tax lawyer structures your expatriation with a US LLC + Paraguay residency, they may be required to report this arrangement to the tax authorities. The arrangement is not illegal, but it is reported = the tax authorities know what you are doing.
DAC7	2021	Automatic exchange of information on digital platform income (Airbnb, Amazon Marketplace, Uber, Fiverr, Upwork).	If you sell on Amazon, rent on Airbnb, or freelance on Upwork from a European address, your income is automatically reported to the tax authorities. Impact for expatriates in PY: low if you no longer use European platforms.
DAC8	2023	Automatic exchange of information on crypto-assets (transposition of CARF — Crypto-Asset Reporting Framework).	European crypto platforms (Kraken EU, Coinbase EU) automatically report your crypto transactions. See our CRS guide section DAC8.

The observation is clear: each directive adds a layer of transparency. In 2011, the tax authorities had to request specific information about a specific taxpayer. In 2026, they will automatically receive data on your bank accounts, crypto accounts, platform income, tax arrangements, and corporate structures — without asking. The information asymmetry between the taxpayer and the tax authorities has been reversed: the tax authorities often know more about your finances than you do.

DAC9: What Changes in 2026

The Content of the Directive

DAC9 is a continuation of previous DACs and brings several advancements in intra-European tax cooperation:

• Strengthening administrative cooperation: DAC9 improves the mechanisms for exchanging information between European tax administrations — particularly for joint tax audits. Two tax administrations (for example, the French DGFiP and the Luxembourg administration) can now conduct a coordinated tax audit on the same taxpayer or structure, with a harmonized legal framework for sharing evidence and conclusions.
• Extension of the scope of automatic reporting: DAC9 extends the categories of assets and income subject to automatic exchange. Discussions include real estate (automatic reporting of real estate owned by non-residents in EU countries), trusts and foundations (reporting of beneficial owners), and certain insurance products not covered by DAC2.
• Harmonization of sanctions: DAC9 pushes for the harmonization of sanctions for non-compliance with reporting obligations (common minimum sanctions for financial institutions that do not report, for intermediaries that do not report DAC6 arrangements, etc.).
• Interconnection of registers: DAC9 promotes the interconnection of national registers (beneficial ownership registers, land registers, vehicle registers) to allow tax administrations to directly access data from other Member States without going through a formal request.
• Use of AI and big data: DAC9 encourages tax administrations to use artificial intelligence to cross-reference received data (CRS, DAC6, DAC7, DAC8) and identify at-risk profiles — including expatriates who have left the EU for countries with advantageous tax regimes.

Key Points for Expatriates

Among the advancements of DAC9, three points directly impact expatriates outside the EU (such as Paraguayan residents of French origin):

Point 1: Cross-border Real Estate Reporting

DAC9 introduces (or reinforces, depending on the versions under negotiation) the automatic exchange of information on real estate owned by non-residents in EU countries:

• If you are a Paraguayan resident and own an apartment in Paris (via a SCI or in your own name), property data (owner's identity, cadastral value, rental income if declared) will be automatically transmitted to the Paraguayan DNIT.
• Conversely, if a French resident owns a property in Paraguay, Paraguay (if it adheres to the framework — which is not certain in 2026) would transmit the data to the DGFiP.
• Practical impact for an expatriate in PY with real estate in France: France already knows that you have real estate (FICOBA, land register, 2044 declaration). DAC9 does not change much for France — but it allows Paraguay to know that you have property in France (useful for the DNIT if it wanted to check the source of certain income — in practice, with no tax consequence since French real estate income is French source, not Paraguayan).

Point 2: Joint Tax Audits

DAC9 facilitates joint tax audits between two EU administrations:

• Relevant scenario: you have a Luxembourg holding company that holds your life insurance. The French DGFiP and the Luxembourg administration can conduct a joint audit on the structure, with real-time information sharing.
• Impact for expatriates in PY: if you have structures in the EU (Luxembourg holding, Luxembourg life insurance, French SCI, Wise Belgium/Lithuania account), European administrations can coordinate to have a complete view of your European assets. This is not new in itself (information exchange on request already existed) but DAC9 makes it faster, smoother, and more systematic.
• Paraguay is NOT in the EU, so DAC9 joint audits do not directly extend to Paraguay. But information collected via intra-EU audits can be used by France in a unilateral tax audit against you (if France claims your residency).

Point 3: AI and Expatriate Targeting

DAC9 encourages the use of artificial intelligence and data mining by tax administrations:

• The DGFiP already cross-references CRS data (foreign accounts), DAC6 (tax arrangements), DAC7 (platforms), DAC8 (crypto), FICOBA (French accounts), and land registers. DAC9 systematizes and automates these cross-references via AI.
• In concrete terms: an algorithm can automatically identify "at-risk" profiles — for example, a taxpayer who declared €200,000 in income and then disappears from the radar (no more declaration) the following year. The algorithm cross-references with CRS data (did they open an account abroad?), real estate data (did they sell or keep their property?), and DAC6 data (did an intermediary declare an expatriation arrangement?). Result: an audit file is automatically generated and assigned to an inspector.
• Impact for expatriates in PY: tax audits of expatriates will become more systematic and faster. Files that went unnoticed ("discreet" expatriations) will be increasingly detected automatically. This is not a problem if your expatriation is legitimate and well-documented — but it is a problem if you have cut ties fiscally without cutting factual ties (family, housing, assets in France).

DAC9 and Non-EU Countries: Is Paraguay Concerned?

The Legal Framework

The DAC directives are legal standards of the European Union. They apply to EU member states and, by extension, to EEE (European Economic Area: Norway, Iceland, Liechtenstein) countries. Paraguay is not a member of the EU or EEE — therefore, it is not directly subject to the DACs.

However, the DACs have an indirect impact on non-EU countries in three ways:

• European financial institutions: banks, brokers, and insurers based in the EU (Interactive Brokers Ireland, Wise Belgium/Lithuania, Luxembourg insurers) are subject to the DACs. They report the accounts of ALL their non-resident clients, including Paraguayan residents. You don't need to be in the EU for the DACs to affect you — you just need to have an account in the EU.
• The global CRS: DAC2/DAC8 are the transposition into EU law of the OECD's global CRS. Paraguay participates in the CRS (outside the EU framework) and already exchanges the same information as that provided by DAC2. The CRS and DACs overlap for participating countries in both frameworks.
• Diplomatic pressure: the EU uses the DACs as leverage to push third countries to adopt equivalent standards. If a country refuses to cooperate at the level required by the DACs, it risks being blacklisted by the EU = economic sanctions. Paraguay cooperates sufficiently (CRS, Multilateral Convention) to stay off the blacklist.

What DAC9 Specifically Changes for a Paraguayan Resident

Situation	Before DAC9	After DAC9	Real Impact
You have an Interactive Brokers account (Ireland)	IB reports your balances and income to the DNIT (CRS/DAC2)	Same + data potentially cross-referenced by the DGFiP's AI if France disputes your residency	Low if PY residency is well established
You have life insurance in Luxembourg	The insurer reports to the DNIT (CRS/DAC2)	Same + joint FR-LU audit possible (DAC9) if France targets your structure	Low if the structure is legitimate
You have real estate in France (SCI)	France knows your SCI (land register, FICOBA). No automatic exchange with PY.	DAC9 strengthens intra-EU real estate reporting. PY could receive FR real estate data (if bilateral framework).	Low. The DNIT cannot tax anything (FR real estate = FR source, not PY).
Your French lawyer structured your expatriation	DAC6: the lawyer may have reported the arrangement to the DGFiP.	DAC9: the DGFiP's AI automatically cross-references the DAC6 declaration with CRS and real estate data.	Moderate. Automatic cross-referencing makes an audit more likely. But if the arrangement is legitimate, the audit concludes in your favor.
You sell on Amazon Marketplace (EU platform)	DAC7: Amazon reports your income to the tax authorities of your declared residency.	DAC9: automatic cross-referencing of DAC7 + CRS + DAC6 to detect inconsistencies.	Low if you have correctly declared your PY residency to Amazon.
You trade on Kraken EU (crypto)	DAC8: Kraken reports your crypto transactions.	DAC9: automatic cross-referencing of DAC8 + CRS to detect inconsistencies.	Low if PY residency is declared correctly.

In summary: DAC9 does not create new categories of information exchanged for Paraguayan residents. It improves the operational capacity of information already collected (by DAC2 to DAC8) by European tax administrations. The volume of information remains the same — but the intelligence with which this information is analyzed increases.

Data Cross-Referencing by AI: The Silent Revolution

How the DGFiP Uses AI in 2026

The French DGFiP is one of the most advanced tax administrations in the world in the use of AI and data mining:

• CFVR Project (Targeting Fraud and Query Valorization): an AI system that analyzes millions of tax declarations and detects anomalies (inconsistent income, unexplained assets, discrepancies between lifestyle and declared income).
• Innovative Land Project: use of satellite and aerial imagery to detect undeclared constructions (swimming pools, extensions, buildings). Not directly related to expatriates but illustrates the technological level of the DGFiP.
• Social media exploitation: algorithms scan public social networks (LinkedIn, Instagram, Facebook) to detect inconsistencies between declared residency and apparent lifestyle. A taxpayer who claims to be a Paraguayan resident but posts daily Instagram stories from Paris is an automatic red flag.
• Cross-referencing CRS + FICOBA + land register + DAC6 + DAC7 + DAC8: all these data sources are interconnected in a centralized data warehouse. AI identifies at-risk profiles by cross-referencing weak signals: disappearance from tax declaration + maintenance of an active French bank account + unsold real estate + DAC6 declaration of an expatriation arrangement = high-risk score = automatic audit.

What the DGFiP's AI Sees When You Go to Paraguay

If you were a French tax resident and you expatriate to Paraguay, here's what the DGFiP's AI can automatically detect:

1. Signal 1: disappearance of your 2042 declaration from year N onwards (you no longer declare in France = departure signal).
2. Signal 2: CRS data shows that your accounts abroad (Interactive Brokers, Wise, Mercury) have changed their declared tax residency → from "France" to "Paraguay".
3. Signal 3: DAC6 — your tax lawyer may have declared an expatriation arrangement to a territorial country (Paraguay) with the creation of a US LLC. The arrangement is reported to the DGFiP.
4. Signal 4: FICOBA shows that your Boursorama account is still open and active (regular movements).
5. Signal 5: the land register shows that you still own an apartment in Lyon (or an SCI).
6. AI Analysis: declared departure + reported expatriation setup + active French account + unsold real estate = HIGH risk score. The file is transferred to an inspector for review.
7. Inspector's Action: sends a request for information (registered mail) asking you to justify your residence abroad (DNIT tax residency certificate, Paraguayan lease, proof of presence).

This process is now largely automated thanks to DAC9 and the DGFiP's technological investments. In 2020, an inspector had to manually cross-reference this data. In 2026, AI cross-references it in a few seconds and automatically generates audit files.

Why this is good news for legitimate expatriates

Paradoxically, the automation of AI-based control is good news for expatriates who have done things correctly:

• Better targeted controls: AI targets genuinely problematic cases (false residence, artificial schemes, hidden assets) and ignores legitimate cases. If your file is clean (no active French account, no unjustified SCI, no "available" real estate, DNIT certificate obtained), your risk score will be low → no audit.
• Faster resolution: when an audit is triggered, the inspector already has all the data. If your evidence file is solid (DNIT certificate, lease, invoices, presence log), the audit is resolved quickly (the evidence is clear and indisputable). Vague files drag on for years.
• Fewer random checks: with AI, random checks (which could affect anyone) are replaced by targeted checks (based on risk indicators). If you have no risk indicators, you are not audited.

Transparency works in your favor when your position is legitimate. Territorial Paraguay + effective residence + DNIT certificate + severance of French ties = unassailable position. DGFiP's AI confirms this position instead of threatening it.

DAC6 and expatriation to Paraguay: what your lawyer must declare

DAC6 Reminder

DAC6 (2018, effective since 2020) obliges "intermediaries" (tax lawyers, accountants, bankers) to declare to tax authorities cross-border tax arrangements that present certain "hallmarks" of aggressive tax optimization. Hallmarks include:

• Hallmark A: confidentiality clause (the client asks the intermediary not to disclose the arrangement to the administration).
• Hallmark B: the arrangement involves a transfer of residence to a low-tax country AND one of the following criteria is met (conversion of income, use of interposed entities, circular structures, etc.).
• Hallmark C: cross-border transactions involving entities in low-tax or non-information exchange jurisdictions.
• Hallmark D: arrangements that undermine CRS/DAC2 reporting (transfer of accounts to non-CRS jurisdictions to avoid automatic exchange).
• Hallmark E: artificial transfer pricing structures.

Is expatriation to Paraguay a "declarable arrangement"?

The question is nuanced:

• Simple expatriation is NOT declarable: moving from Paris to Asunción to live and work there is not a "tax arrangement". It's a lifestyle choice. No DAC6 hallmark is met by the mere fact of settling in another country.
• Structured expatriation MAY be declarable: if your tax lawyer structures your departure with a US LLC (entity in a favorable tax jurisdiction) + residence in Paraguay (territorial country = low taxation) + asset transfer (SCI sale, PEA closure, life insurance transfer), certain hallmarks may be met — notably Hallmark B (transfer of residence + income conversion via LLC) and Hallmark C (transactions via a low-tax jurisdiction).
• A DAC6 declaration is not an accusation: the fact that your lawyer declares the arrangement DOES NOT mean that the arrangement is illegal or fraudulent. DAC6 is a transparency tool, not a sanction. The declaration informs the tax authorities of the arrangement — the tax authorities then decide whether or not to examine it. The majority of arrangements declared under DAC6 are perfectly legal.
• Practical impact: the DGFiP receives the DAC6 declaration, notes that a taxpayer has structured an expatriation to Paraguay with a US LLC, and adds this file to its database. The AI cross-references this information with other data (CRS, FICOBA, land registry). If everything is consistent (the taxpayer has indeed left France, no longer has significant ties, is effectively resident in Paraguay), the file remains on standby. If inconsistencies appear, an audit is triggered.

Should we be afraid of DAC6?

No — if your expatriation is legitimate. DAC6 makes your arrangement visible, not illegal. It's the substance that matters, not the visibility: if you actually live in Paraguay, your income is legitimately from foreign sources, and your residence is documented, the DAC6 declaration merely confirms that you have done things by the book.

The real risk of DAC6 is for fictitious expatriations: taxpayers who claim to live in Paraguay but remain in France. DAC6 + AI = near-certain detection. This is all the more reason to make a real expatriation — not a letterbox.

The impact of DAC9 on common structures for expatriates in Paraguay

Structure 1: US LLC + Mercury Bank + PY residence

• Current transparency (pre-DAC9): Mercury Bank reports to the IRS (FATCA). The IRS can transmit to Paraguay (limited bilateral agreements). The arrangement may have been declared DAC6 by the intermediary who structured it.
• After DAC9: no direct change (Mercury Bank is in the USA, outside DAC scope). Indirect change: if France challenges your residence, it will more effectively cross-reference existing data to build its argument.
• Risk level: unchanged. The structure is legitimate and documented.

Structure 2: Luxembourg life insurance

• Current transparency: the Luxembourg insurer reports to Paraguay via CRS (balances, redemptions). DAC6 possible if the transfer to Luxembourg was structured as an optimization arrangement.
• After DAC9: joint FR-LU control possible if France targets your structure. The Luxembourg administration and the DGFiP can share real-time information on your contract.
• Risk level: low. Luxembourg life insurance is a standard product, not an exotic arrangement. The Luxembourg security triangle is recognized and regulated. The risk is only if France challenges your residence (in which case, redemptions could be taxed in France if you are reclassified as a resident).

Structure 3: French SCI held from Paraguay

• Current transparency: the SCI is declared in the French land registry. Income is declared in France (rental income from French sources). Non-residents pay withholding tax on rental income.
• After DAC9: enhanced real estate reporting can automatically transmit your SCI data to Paraguay. AI cross-referencing can note that you have an SCI in France → "center of economic interests" indicator → audit if other indicators are present.
• Risk level: moderate. The SCI in France is a link with France that the tax authorities can use. If the SCI is your only link (no home, no stay, no activity), the risk is manageable. If the SCI is added to other links (available housing, active account, family), the body of evidence becomes heavier.

Structure 4: Crypto account on EU exchange

• Current transparency: DAC8 → Kraken EU, Coinbase EU report your crypto transactions to the Paraguayan DNIT (if you have declared yourself a PY resident).
• After DAC9: automatic DAC8 + CRS cross-referencing. AI can detect an inconsistency if your declared residence at Kraken (Paraguay) does not match your declared residence at your French bank (if you forgot to update).
• Risk level: low if self-certifications are consistent everywhere. High if there is a residence inconsistency between institutions.

The anti-DAC9 strategy: total consistency

The fundamental principle

Faced with the European transparency arsenal (DAC1 to DAC9, CRS, FATCA, FICOBA), the strategy is not secrecy — it is consistency. Every financial institution, every registry, every administration must have the same information about you:

• Tax residence: Paraguay. Everywhere. At Mercury, at Interactive Brokers, at Wise, at your French bank (non-resident PY), at your Luxembourg insurer, at Kraken, at Amazon. The same declared residence everywhere.
• Address: your address in Asunción. Everywhere. Not an old French address forgotten in a form.
• TIN: your Paraguayan RUC. Everywhere. Not your old French tax number (except on your French non-resident declarations if you have French-source income).

The DGFiP's AI looks for inconsistencies. If everything is consistent, the AI finds nothing → no audit. If one institution says "resident France" and another says "resident Paraguay", the AI detects the inconsistency → audit.

The DAC9 checklist for expatriates in Paraguay

1. Check the declared residence with each financial institution (see our CRS guide for the detailed checklist). Residence = Paraguay + RUC everywhere.
2. Convert your French bank account to non-resident. Inform the bank of your residence in Paraguay. Provide the cedula and RUC.
3. Reduce exploitable French ties for AI: sell or rent the property, put the SCI under management, reduce movements on the French account, close unnecessary French subscriptions.
4. Obtain and keep the DNIT tax residency certificate. This is your ultimate proof. Renew it annually.
5. Document your effective residence: lease, invoices, Paraguayan bank statements, presence log. These documents contradict any attempt at reclassification.
6. Inform your tax lawyer of the DAC6/DAC9 context. If they declared a DAC6 arrangement during your expatriation, ensure that the arrangement is documented as legitimate (real substance in Paraguay, no artificial arrangement).
7. Check your online profiles: LinkedIn, Instagram, Facebook. Location = Asunción, Paraguay. Not "Paris, France" forgotten since 2023.
8. Archive everything. Keep 10 years of proof (duration of French tax recovery right in case of fraud). Leases, invoices, statements, DNIT declarations, flight tickets, residency certificates. Digital and paper.

DAC9 and other French-speaking countries

Belgium and DAC9

Belgium, as an EU member, applies DAC9 in full. Belgian expatriates in Paraguay face the same challenges as French expatriates:

• The Belgian tax administration (FPS Finance) receives the same CRS, DAC6, DAC7, DAC8 data as the DGFiP.
• Joint DAC9 controls apply between Belgium and other EU countries.
• Belgium also uses data mining tools (FPS Finance Datamining system).
• Deletion from the national register remains the critical step for severing Belgian residence — DAC9 does not change this point but makes post-deletion inconsistencies more visible.

Switzerland and DAC9

Switzerland is not an EU member but is partially in the EEA (bilateral agreements). Switzerland applies CRS and equivalent information exchange agreements to DACs. DAC9 specifically does not apply directly to Switzerland, but the principles (AI, data cross-referencing, enhanced cooperation) are adopted by the Swiss FTA via equivalent mechanisms.

Canada and DAC9

Canada is not in the EU and is not subject to DACs. But Canada applies CRS and has its own detection tools (CRA data analytics). Canadian expatriates in Paraguay are not affected by DAC9 but are subject to equivalent mechanisms on the Canadian side.

The 2027-2030 outlook: towards DAC10?

What might come after DAC9

The EU will not stop at DAC9. Discussions on DAC10 (or an extension of DAC9) focus on:

• Real estate outside the EU: oblige member states to collect and exchange information on real estate held by their residents in third countries (currently limited to intra-EU properties). If a French resident owns a property in Paraguay, France should be automatically informed. This would require a bilateral agreement with Paraguay — not yet under discussion.
• Digital assets beyond crypto: NFTs, value tokens, tokenized assets (tokenized real estate, tokenized shares). The evolution of DAC8 towards covering all digital assets.
• Family offices and trusts: more detailed reporting of family wealth management structures (beneficiaries, flows, assets held).
• Global interoperability: connecting the EU's DAC system with equivalent systems in third countries (CRS+, FATCA) to create a seamless global network of tax transparency.

The trend is clear: more transparency, more cross-referencing, more automation. Each successive DAC reduces grey areas. By 2030, it is likely that European tax administrations will have an almost complete view of the assets of their taxpayers (and former taxpayers) worldwide.

For an expatriate in Paraguay, this changes nothing fundamental: transparency is not a problem when the law of your country of residence exempts your foreign income. DACs transmit data. Paraguay does not tax them. The loop is closed.

Conclusion

DAC9 is the ninth brick in the European edifice of tax transparency. It strengthens administrative cooperation between European tax authorities, facilitates joint controls, extends real estate reporting, and — above all — systematizes the use of AI and data mining to cross-reference the billions of data collected over the past 15 years (CRS, DAC2-DAC8, FICOBA, land registries, social networks).

For expatriates in Paraguay, DAC9 creates no new obligations and no new taxes. But it makes tax controls more automated, more targeted, and more efficient. The DGFiP's AI detects inconsistent expatriations (claiming to live in Paraguay while maintaining significant ties in France) with increasing precision.

The answer is not fear or opacity — it is total consistency. Same declared residence everywhere (Paraguay), same address (Asunción), same TIN (RUC). Severance of exploitable French ties. DNIT tax residency certificate. Archived evidence file for 10 years. Up-to-date online profiles.

In a world of total transparency, the best strategy is to have nothing to hide — and to live in a country where transparency generates no tax. Paraguay is that country. DAC9 confirms it.

Do you want a tax-proof expatriation from DAC9? Contact our team for comprehensive support: Paraguayan residency (from €1,400), consistency of all your CRS self-certifications, DNIT accounting (€30/month), and coordination with your tax lawyer for an irreproachable anti-audit file. Transparency is your ally — provided you are on the right side of the law.