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Date: 2025-10-17 Category: Not Applicable State: Union Government Country: Europe

Council Decision (EU) 2025/2124 of 10 October 2025 on the signing, on behalf of the Union, of the Amending Protocol to the Agreement between the European Union and the Principality of Liechtenstein on the automatic exchange of financial account information to improve international tax compliance

Issued by Council of the European Union · Not Applicable

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Executive Summary & Key Takeaways

**Executive Summary** This Council Decision (EU) 2025/2124, dated October 10, 2025, authorizes the signing, on behalf of the European Union, of the Amending Protocol to the Agreement with the Principality of Liechtenstein. The protocol concerns the automatic exchange of financial account information to improve international tax compliance. The decision also approves the Joint Declarations attached to the Amending Protocol. This Decision enters into force on the date of its adoption, October 10, 2025. **Key Points / Main Content** * **Authorization of Signature:** The signing of the Amending Protocol between the EU and Liechtenstein is authorized on behalf of the Union, contingent upon the conclusion of the Amending Protocol. * **Approval of Joint Declarations:** The Joint Declaration of the Contracting Parties on Article 5 of the Agreement and the Joint Declaration of the Contracting Parties on the entry into force and effect of the Amending Protocol are approved on behalf of the Union. * **Entry into Force:** This decision enters into force on the date of its adoption. * **Background Context:** * The original Agreement between the EU and Liechtenstein enhanced mutual assistance in tax matters. * Important changes to the Common Reporting Standard (CRS) were approved internationally in August 2022 and were incorporated into Union law by means of Council Directive (EU) 2023/2226. * Negotiations with Liechtenstein for amending the Agreement to reflect the changes to the CRS were successful. * The negotiating directives required updating data protection legislation references. * The European Data Protection Supervisor was consulted according to Regulation (EU) 2018/1725. * Liechtenstein has implemented Regulation (EU) 2016/679. **Impact Analysis** **European Union** * **Impact:** The EU is bound by the Amending Protocol once signed and concluded, improving international tax compliance. * **Action Required:** Sign and conclude the Amending Protocol. **Principality of Liechtenstein** * **Impact:** Liechtenstein is bound by the Amending Protocol once signed and concluded, improving international tax compliance. * **Action Required:** Sign and conclude the Amending Protocol. **Tax Authorities of EU Member States and Liechtenstein** * **Impact:** Enhanced access to financial account information for improved tax compliance. * **Action Required:** Adapt systems and procedures to incorporate the changes to the CRS as per the Amending Protocol. **Financial Institutions in EU Member States and Liechtenstein** * **Impact:** Modification to reporting requirements for financial account information. * **Action Required:** Implement necessary changes to their reporting systems to comply with the updated CRS standards outlined in the Amending Protocol.

Key Entities Referenced

Amending Protocol to the Agreement between the European Union and the Principality of Liechtenstein: Protocol amending the existing agreement on the automatic exchange of financial account information to improve international tax compliance, reflecting changes to the Common Reporting Standard (CRS). Council Directive (EU) 2023/2226: Directive amending Directive 2011/16/EU on administrative cooperation in the field of taxation to incorporate changes to the Common Reporting Standard (CRS) into Union law. Council Directive 2011/16/EU: Directive on administrative cooperation in the field of taxation, which is being amended to reflect changes in the Common Reporting Standard. European Union: One of the parties to the agreement on the automatic exchange of financial account information. Principality of Liechtenstein: One of the parties to the agreement on the automatic exchange of financial account information.
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Official Journal EN of the European Union L series 2025/2124 17.10.2025 COUNCIL DECISION (EU) 2025/2124 of 10 October 2025 on the signing, on behalf of the Union, of the Amending Protocol to the Agreement between the European Union and the Principality of Liechtenstein on the automatic exchange of financial account information to improve international tax compliance THE COUNCIL OF THE EUROPEAN UNION, Having regard to the Treaty on the Functioning of the European Union, and in particular Article 115, in conjunction with Article 218(5) and Article 218(8), second subparagraph, thereof, Having regard to the proposal from the European Commission, Whereas: (1) The Agreement between the European Union and the Principality of Liechtenstein on the automatic exchange of financial account information to improve international tax compliance(1) (‘the Agreement’) has enhanced mutual assistance in tax matters between the Contracting Parties and improved international tax compliance. (2) Important changes to the Common Reporting Standard (CRS) of the Organisation for Economic Cooperation and Development were approved at international level on 26 August 2022 and were incorporated into Union law by means of Council Directive (EU) 2023/2226(2), which amended Council Directive 2011/16/EU(3). (3) On 21 May 2024, the Council authorised the Commission to open negotiations with the Principality of Liechtenstein (‘Liechtenstein’) for an amendment of the Agreement to reflect the changes to the CRS approved at the international level. The negotiations were successfully concluded with the initialling of the Amending Protocol to the Agreement between the European Union and the Principality of Liechtenstein on the automatic exchange of financial account information to improve international tax compliance (‘the Amending Protocol’). (4) The negotiating directives also required the Commission to update the references to the data protection legislation of the Contracting Parties. (5) The text of the Amending Protocol, which is the result of the negotiations, duly reflects the negotiating directives issued by the Council. (6) Therefore, the Amending Protocol should be signed on behalf of the Union and the Joint Declarations attached to the Amending Protocol should be approved. (7) The European Data Protection Supervisor was consulted in accordance with Article 42(1) of Regulation (EU) 2018/1725 of the European Parliament and of the Council(4). (8) Liechtenstein has, on the basis of its membership of the European Economic Area, implemented Regulation (EU) 2016/679 of the European Parliament and of the Council(5) by means of the Data Protection Act of 4 October 2018, HAS ADOPTED THIS DECISION: (1) OJ L 379, 24.12.2004, p. 84, ELI: http://data.europa.eu/eli/agree_internation/2004/897/oj. (2) Council Directive (EU) 2023/2226 of 17 October 2023 amending Directive 2011/16/EU on administrative cooperation in the field of taxation (OJ L, 2023/2226, 24.10.2023, ELI: http://data.europa.eu/eli/dir/2023/2226/oj). (3) Council Directive 2011/16/EU of 15 February 2011 on administrative cooperation in the field of taxation and repealing Directive 77/799/EEC (OJ L 64, 11.3.2011, p. 1, ELI: http://data.europa.eu/eli/dir/2011/16/oj). (4) Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the protection of natural persons with regard to the processing of personal data by the Union institutions, bodies, offices and agencies and on the free movement of such data, and repealing Regulation (EC) No 45/2001 and Decision No 1247/2002/EC (OJ L 295, 21.11.2018, p. 39, ELI: http://data.europa.eu/eli/reg/2018/1725/oj). (5) Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119, 4.5.2016, p. 1, ELI: http://data.europa.eu/eli/reg/2016/679/oj). ELI: http://data.europa.eu/eli/dec/2025/2124/oj 1/2EN OJ L, 17.10.2025 Article 1 The signing of the Amending Protocol to the Agreement between the European Union and the Principality of Liechtenstein on the automatic exchange of financial account information to improve international tax compliance is hereby authorised on behalf of the Union, subject to the conclusion of the said Amending Protocol(6). Article 2 The Joint Declaration of the Contracting Parties on Article 5 of the Agreement and the Joint Declaration of the Contracting Parties on the entry into force and effect of the Amending Protocol are hereby approved on behalf of the Union. Article 3 This Decision shall enter into force on the date of its adoption. Done at Luxembourg, 10 October 2025. For the Council The President S. LOSE (6) The text of the Amending Protocol will be published together with the decision on its conclusion. 2/2 ELI: http://data.europa.eu/eli/dec/2025/2124/oj

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