EU agrees pillar two global minimum tax rate

International Tax Review is part of Legal Benchmarking Limited, 4 Bouverie Street, London, EC4Y 8AX

Copyright © Legal Benchmarking Limited and its affiliated companies 2024

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

EU agrees pillar two global minimum tax rate

EU - pillar two.jpg

Hungary lifts its veto as the EU takes the lead on applying the OECD’s pillar two agreement.

EU member states achieved a historic breakthrough yesterday, December 12, by agreeing to implement the OECD’s global corporate minimum tax rate of 15% across the bloc.

The decision to adopt the minimum tax rate, known as pillar two, came after the Hungarian government dropped the last remaining objection to applying the measure in the EU.

EU ambassadors released some post-COVID recovery funds, which had previously been blocked due to a rule of law dispute between Hungary and the bloc, in exchange for Budapest lifting its veto to the tax floor rate.

Zbyněk Stanjura, finance minister of the Czech Republic, which holds the rotating presidency of the Council of the EU, welcomed the agreement as a clear and strong message to businesses on tax.

“The largest groups of corporations, multinational or domestic, will need to pay a corporate tax that cannot be lower than 15% globally,” he said in a statement.

The landmark two-pillar solution, which was reached at the OECD Inclusive Framework by 137 countries in October 2021, represents the most wide-reaching attempt to reduce profit-shifting by global corporations.

Pillar two aims to ensure that large multinationals with revenues of at least €750 million ($790 million) pay an international minimum effective tax rate of 15% in all the countries in which they operate.

Meanwhile, pillar one would overhaul international taxing rights to ensure that multinationals declare profits and pay tax in the jurisdictions where they do business. The measure would apply to large multinationals with revenues exceeding €20 billion ($21.1 billion).

The EU’s minimum tax rate move is seen as crucial to saving pillar two after the measure had gone cold on both sides of the Atlantic due to fierce political and business resistance.

European ambassadors have now set the ball rolling on applying the tax floor rate by advising the Council of Ministers to formally adopt the pillar two directive. The EU law is expected to be transposed into member states’ domestic rules by the end of 2023.

more across site & bottom lb ros

More from across our site

ITR’s most interesting stories of the year covered ‘landmark’ legal battles, pillar two, AI’s relationship with transfer pricing and more
Chinwe Odimba-Chapman was announced as Michael Bates’ successor; in other news, a report has found a high level of BEPS compliance among OECD jurisdictions
The tool, which will automatically compute amount B returns, requires “only minimal data inputs”, according to the OECD
The rules are intended to implement the substance of an earlier OECD report in its entirety
While new technology won’t replace the human touch, it could help relieve companies’ staffing issues, EY’s David Helmer and Daren Campbell tell ITR
The firm said the financial growth came from increased demand for its AI services and global tax reform advice
Chrystia Freeland had also been the figurehead of Canada’s controversial digital services tax adoption, which stoked economic tensions with the US
Panama has no official position on pillar two so far and a move to implement in Costa Rica will face rejection, experts tell ITR
The KPMG partner tells ITR about Sri Lanka’s complex and evolving tax landscape, setting legal precedents through client work, and his vision for the future of tax
Overall turnover at the firm also reached a record £8 billion; in other news, Ashurst and Dentons announced senior tax partner hires
Gift this article